HomeMy Public PortalAboutphase-ii-stormwater-mgmt-plan-2008-13ST. LOUIS COUNTY
PHASE II
S TORM WATER MANAGEMENT PLAN
SECOND PERMIT TERM
2008 - 2013
PREPARED FOR ST. LOUIS COUNTY MUNICIPALITIES
BY
THE ST. LOUIS MUNICIPALITIES PHASE II STORM WATER PLANNING COMMITTEE
SUMMER 2007
CONSTRUCTION
SITE CONTROLS
ILLICIT DISCHARGE
DETECTION
post construction
management
PUBLIC EDUCATION
public
involvement
Municipal
pollution prevention
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St. Louis County Phase II Storm Water Management Plan
Prepared by
The St. Louis Municipalities Phase II Storm Water Planning Committee
Scott Douglass
Mayor
City of Clarkson Valley
Russell Leach, P.E.
Assistant Division Manager, Construction
St. Louis County Highways & Traffic
Paul Wojciechowski, AICP, PE
Director of Public Works
City of Clayton
Gail Ottolino-Choate
Land Use Manager
St. Louis County Planning
Bill Schwer, P.E.
Director of Public Works
Ciy of Ellisville
Pat Palmer
Division Manager Highway Operations
St. Louis County Highways & Traffic
Dennis Bible
Director of Public Works
City of Ladue
Charles Thien
Operations Manager
St. Louis County Highways & Traffic
Cliff Baber, P.E.
Construction Manager
City of Maryland Heights
Ray Gawlik
Storm Water Manager
St. Louis County Highways & Traffic
Bryan Pearl, P.E.
Director of Public Works
City of Maryland Heights
Bill Seffens
Waste Management Specialist
St. Louis County Health Department
Michael McDowell
City Manager
City of Olivette
Michael Buechter, P.E.
Principal Engineer
Metropolitan St. Louis Sewer District
Steve Nagle
Director of Planning
East-West Gateway Council of Governments
Mark Koester, P.E.
Principal Engineer
Metropolitan St. Louis Sewer District
Ruth Wallace
State MS4 Program Coordinator
Missouri Department of Natural Resources
Joyce Theard
Environmental Specialist
Metropolitan St. Louis Sewer District
Michael Bardot
Assistant Division Manager
St. Louis County Highways & Traffic
James Bergmann
Environmental Specialist
Metropolitan St. Louis Sewer District
Pat Detch
Urban Planner
St. Louis County Planning
Bruce H. Litzsinger, P.E.
Manager of Environmental Compliance
Metropolitan St. Louis Sewer District
Summer 2007
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Executive Summary
The Phase II Storm Water Regulations were promulgated to provide appropriate storm
water management for political subdivisions in urbanized areas which were exempted
under the 1990 (Phase I) regulations. Exemption of certain urbanized areas because of
the size of the political subdivisions created so-called “donut holes” in the national storm
water program. Appendix 6, Governmental Entities Located Fully or Partially Within an
Urbanized Area, of the preamble to the USEPA’s December 8, 1999 rule listed nearly all
of the political subdivisions in St. Louis County as entities requiring a Phase II NPDES
Permit. The St. Louis metropolitan area may have been the largest “donut hole” in the
nation because of combined sewers serving the City of St. Louis and the numerous
small political subdivisions in St. Louis County.
Missouri’s Phase II Storm Water Regulations for small MS4s are contained in 10 CSR
20-6.200. The statute allows three permit options for small MS4 discharges: a general
permit, a site specific permit, or a co-permittee option. It is emphasized in the
regulations at (5)(C)1 that:
“the department encourages cooperation between potential small MS4
applicants when addressing application requirements and in the
development, implementation and enforcement of the six minimum
measures under issued permits.”
It is also stated that:
“applicants within one urbanized area…should consider applying as co-
applicants…to become co-permittees under an issued permit.”
There is a “patchwork” of political jurisdictions in St. Louis County connected by shared
streets and highways. Utilities are provided on a regional basis by both private and
public entities. The Metropolitan St. Louis Sewer District (MSD) provides collection and
treatment of wastewaters generated by residential, commercial and industrial activities.
The MSD is also responsible for operation and maintenance of the separate storm
sewer systems serving all of the municipalities in the St. Louis County area.
Many communities provide services such as trash pickup under private contract.
Permitting each municipality separately under the Phase II Regulations did not seem
appropriate or administratively feasible because of service overlap. The topography of
the area suggested individual municipal permits with respect to storm water conveyance
identification would be overly complex with possible jurisdictional disputes. Natural
watercourses often leave one municipality, enter the jurisdictional boundaries of a
second or third municipality and re-enter a portion of the first municipality. Individual
municipal permits were not considered a viable means of insuring control of storm water
pollutants to the maximum extent practicable.
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St. Louis County storm water drains into three major watersheds: the Mississippi River,
the Meramec River, and the Missouri River. All storm water runoff from the County
ultimately enters the Mississippi River. The Mississippi River forms the eastern
boundary of the southernmost and northernmost portions of the County with the
remainder entering the western boundary of the City of St. Louis and its combined
sewer system. The Meramec River generally forms the southern boundary of the
County except for a portion in the west of the County where the border includes land
south of the Meramec River that is drained by its tributaries. The Missouri River forms
the northern boundary of the County. Many small tributaries located within the County
feed into each of these three major rivers.
The Metropolitan St. Louis Sewer District (MSD) has been given the responsibility for
providing adequate sewer and drainage facilities within its boundaries by its Charter
(Plan). Under the Phase II Storm Water Regulations, MSD was recognized as the
coordinating authority under the St. Louis Metropolitan Small MS4 Storm Water Permit,
MO-R040005, issued by the Missouri Department of Natural Resources (MDNR) Water
Pollution Control Program. Sixty additional co-permittees were named under the permit.
Under the first permit term ending March 9, 2008, the first St. Louis County Phase II
Storm Water Management Plan Fall 2002 has been implemented.
Public education activities have been implemented, including various methods such as
printed materials, videos, internet, and presentations. During the first permit term, MSD
has developed over nine different brochures and distributed over two million copies.
The pollution prevention video and four infomercials were developed and aired over
three thousand times. An internet web presence was developed, resulting in thousands
of downloads. Finally, over 260 public presentations were given by MSD and its
partners to educate the public. Public involvement and participation activities have
increased significantly under all the programs. Household hazardous waste events
have collected a total of 1,576 tons of hazardous waste. MSD and its community
partners have held 33 clean up events, and placed 7500 storm drain markers on inlets.
Under Minimum Control Measure (MCM) 3, MSD will have surveyed over 1120 stream
miles to identify illegal discharges, walking all the named minor watersheds identified in
the SWMP. Under MCM 4, the co-permittees will have a Phase II land disturbance
program to control construction site runoff. Under post-construction storm water
management, structural and non-structural BMPs are required throughout the plan area
for all new development and redevelopment under MSD’s new Rules and Regulations.
Educational information on planning and zoning strategies to protect water quality have
been distributed, and a baseline for implementation established. Under good
housekeeping for municipal operations in MCM 6, a model operation and maintenance
program has been developed and distributed to all co-permittees, and all co-permittees
will have implemented the program.
This revision of the Storm Water Management Plan for the second permit term
incorporates the implementation of the first Plan, and discusses ongoing and new goals
for improving the effectiveness of the programs. The 2002 Plan will be maintained as a
resource as much of the background information in the original Plan, which was helpful
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for development and implementation of the programs, will not be duplicated. The Phase
II Storm Water program is a regulatory issue that is conducive to forming partnerships to
achieve a common goal. Therefore, the emphasis in this second plan will be to
increase communication with the goal of improving partnerships and education.
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Table of Contents
CHAPTER 1
Phase II Plan Coordination ....................................................................................................................1-1
A. Plan Coverage ..............................................................................................................................1-1
B. Major Watersheds.........................................................................................................................1-3
C. Minor Watersheds ........................................................................................................................1-5
D. Permitting Strategy .......................................................................................................................1-6
E. Selection of a Coordinating Authority ...........................................................................................1-7
F. Establishing a Planning Committee ..............................................................................................1-7
G. Keeping the Community Informed ..............................................................................................1-10
H. Plan Revisions ............................................................................................................................1-10
CHAPTER 2
Demographics of the St. Louis Area ......................................................................................................2-1
CHAPTER 3
Water Quality in St. Louis County Streams ...........................................................................................3-1
A. Missouri Water Quality Standards ................................................................................................3-1
B. Impaired Waters............................................................................................................................3-4
C. USGS Water Quality Monitoring ...................................................................................................3-4
D. Identification of Area Storm Water Pollution Problems/Sources ..................................................3-5
1. Wet Weather Flow Water Quality .............................................................................................3-7
2. Suspended Solids .....................................................................................................................3-8
3. Fecal Coliform ...........................................................................................................................3-9
4. Chloride...................................................................................................................................3-10
5. Trash .......................................................................................................................................3-10
6. Mercury ...................................................................................................................................3-11
CHAPTER 4
Public Education and Outreach (MCM 1)..............................................................................................4-1
A. MS4 Permit Requirements............................................................................................................4-1
B. General Pollution Prevention Compliance Activities.....................................................................4-1
C. Compliance Activities using Printed Material ...............................................................................4-2
D. Compliance Activities using Presentations...................................................................................4-2
E. Compliance Activities using Other Media .....................................................................................4-2
F. Rationale for New Goals ...............................................................................................................4-3
CHAPTER 5
Public Involvement and Participation (MCM 2).....................................................................................5-1
A. MS4 Permit Requirements............................................................................................................5-1
B. Public Involvement in Storm Water Plan Development ................................................................5-1
C. Public Participation Programs ......................................................................................................5-2
D. Pet Owner Responsibilities ...........................................................................................................5-2
E. Rationale for New Goals ...............................................................................................................5-3
CHAPTER 6
Illicit Discharge Detection and Elimination (MCM 3).............................................................................6-1
A. MS4 Permit Requirements............................................................................................................6-1
B. Identification of Storm System Components ................................................................................6-2
C. Illicit Discharge Enforcement Mechanism ....................................................................................6-5
D. Illicit Discharge Detection/Elimination ..........................................................................................6-7
E. Publicizing Hazards Associated With Illicit Discharges ................................................................6-8
F. Rationale for New Goals ...............................................................................................................6-9
CHAPTER 7
Construction Site Storm Water Runoff Control (MCM 4)......................................................................7-1
A. MS4 Permit Requirements............................................................................................................7-1
B. Land Disturbance Requirements ..................................................................................................7-1
C. Land Disturbance Activities ..........................................................................................................7-2
1. Metropolitan St. Louis Sewer District ........................................................................................7-2
2. St. Louis County........................................................................................................................7-2
D. MDNR Land Disturbance Permit Requirements...........................................................................7-3
E. Plan Area Land Disturbance Programs ........................................................................................7-5
1. St. Louis County........................................................................................................................7-5
2. Municipalities ............................................................................................................................7-6
3. Other Entities ............................................................................................................................7-7
F. Rationale for New Goals ...............................................................................................................7-7
CHAPTER 8
Post-Construction Storm Water Management in New Development and Redevelopment (MCM 5)...8-1
A. MS4 Permit Requirements............................................................................................................8-1
B. Program Intent ..............................................................................................................................8-2
C. Best Management Practice Implementation.................................................................................8-2
1. Metropolitan St. Louis Sewer District (MSD)............................................................................8-3
2. Planning and Zoning Authorities ...............................................................................................8-4
3. Missouri Department of Transportation ....................................................................................8-5
D. Flood Control ................................................................................................................................8-5
E. Rationale for New Goals ...............................................................................................................8-7
CHAPTER 9
Pollution Prevention/Good Housekeeping for Municipal Operations (MCM 6).....................................9-1
A. MS4 Permit Requirements............................................................................................................9-1
B. Storm Water Discharges Associated with Industrial Activity ........................................................9-2
C. Storm Water Conveyance Construction and O&M .......................................................................9-2
D. Operation and Maintenance Program ..........................................................................................9-4
E. Municipal Employee Training Program .........................................................................................9-9
F. Trash and Pet Waste Ordinances ...............................................................................................9-10
G. Rationale for New Goals ............................................................................................................9-10
CHAPTER 10
Record Keeping and Reporting ...........................................................................................................10-1
A. MS4 Permit Requirements..........................................................................................................10-1
B. Record Keeping ..........................................................................................................................10-2
C. Reporting ....................................................................................................................................10-3
CHAPTER 11
BMP Goals, Measurements, and Responsibilities ..............................................................................11-1
A. Purpose.......................................................................................................................................11-1
B. BMP Implementation Information ...............................................................................................11-1
C. Effectiveness of BMPs................................................................................................................11-6
APPENDICES
Appendix A3-1 USGS Storm Water Sampling
Appendix A6-1 Storm Water Outlets
Appendix A6-2 Outlet Map Index
Phase II Plan Coordiantion
1-1
CHAPTER 1
Phase II Plan Coordination
A. Plan Coverage
The Metropolitan St. Louis Sewer District (MSD) is a regional sewer district, formed in
1954, under the provisions of Article 6, Section 30(a) of the Missouri constitution. Under
these provisions, voters in the City of St. Louis and in the portion of St. Louis County
roughly east of current Interstate 270, adopted a plan proposed by a board of
freeholders. The size of the district was increased in 1977 through a voter-approved
annexation of most of the rest of St. Louis County east of Highway 109. The
boundaries of the MSD and land area covered by the MSD are shown in Figure 1.1.
This Plan is intended to cover the portion of St. Louis County that is included within the
Metropolitan St. Louis Sewer District boundaries, excluding those county municipalities
which are served by combined sewers or have populations less than 1000. Of the 91
municipalities in St. Louis County, two municipalities, the City of Pacific and the City of
Eureka, are located outside of MSD’s service area. MSD’s boundaries cover
approximately 436 square miles, and will henceforth be referred to as the “Plan Area.”
Although there are 89 municipalities located within MSD’s county service area, only 59
will be co-permittees under this Plan. Of the 89 municipalities, twelve are served by
combined sewers and are, therefore, excluded pursuant to Section (1)(C)16.C of the
Missouri storm water regulation 10 CSR 20-2.600. An additional 18 municipalities are
exempt under the provisions of Section (1)(C)24.A of the regulation based on having
populations less than 1000. These 18 municipalities can be viewed as “donut holes”
within the overall Plan Area. While these communities will not be co-permittees, they
will benefit from some of the activities proposed within this Plan. Figure 1.2 shows the
St. Louis County municipalities and the City of St. Louis.
Of the 59 municipalities which will be co-permittees, 58 lie wholly within the Plan Area.
About 61% of the City of Wildwood, on the western edge of the MSD boundary, lies
outside the Plan Area, but it is anticipated that the city will apply all elements of this Plan
to its entire corporate area. Likewise, St. Louis County will apply all elements of the
Plan to its entire area of jurisdiction. MSD’s western boundary may change slightly as
small voluntary annexations occur. As new areas are annexed into the MSD service
area, they will be fully covered by all elements of the Plan for which MSD and others
have responsibility.
Phase II Plan Coordiantion
Figure 1.1 Map Showing MSD Boundaries
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Phase II Plan Coordiantion
Figure 1.2 Locations of Incorporated Places in St. Louis County
B. Major Watersheds
St. Louis County storm water drains into three major watersheds: the Mississippi River,
the Meramec River, and the Missouri River as illustrated in Figure 1.3. All storm water
runoff from the Plan Area ultimately enters the Mississippi River. The Mississippi River
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Phase II Plan Coordiantion
forms the eastern boundary of the southernmost and northernmost portions of the Plan
Area with the remainder of the Plan Area entering the western boundary of the City of
St. Louis and its combined sewer system. The extent of the combined sewer area is
also shown in Figure 1.3. The Meramec River, tributary to the Mississippi River to the
south, forms the southern boundary of the Plan Area except for a portion of the Plan
Area in which tributaries to the Meramec drain from the south to the north into the
Meramec River. The Missouri River, tributary to the Mississippi on the north, forms the
northern boundary of the Plan Area. Many small tributaries located within the Plan Area
feed into each of these three major rivers.
Figure 1.3 Location of Combined Sewer Area
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Phase II Plan Coordiantion
C. Minor Watersheds
Stream tributaries to the three major watersheds in the Plan Area were studied using
detailed methods by FEMA for the St. Louis County Flood Insurance Study and by
approximate methods. The tributary streams within each major watershed are identified
and described below. Figure 1.4 shows the location of the tributaries within the major
watersheds and Plan Area.
Figure 1.4 Stream Tributaries Within the Plan Area
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Phase II Plan Coordiantion
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D. Permitting Strategy
The State’s Phase II Storm Water Regulations for small MS4s are contained in 10 CSR
20-6.200. The regulations allows three permit options for small MS4 discharges: a
general permit, a site specific permit, or co-permittee option. It is emphasized in the
regulations at (5)(C)1 that:
“the department encourages cooperation between potential small MS4
applicants when addressing application requirements and in the
development, implementation and enforcement of the six minimum
measures under issued permits.”
It is also stated that:
“applicants within one urbanized area…should consider applying as co-
applicants…to become co-permittees under an issued permit.”
The Planning Committee agreed with the State’s regulatory recommendations and has
promoted utilization of the co-permittee option to encourage cooperation among
municipal governments, and so that legal, financial and administrative responsibilities
can be shared.
The 2002 Planning Committee decided to pursue one Phase II Storm Water
Management Plan and one NPDES permit for the entire area of St. Louis County under
MSD’s jurisdiction. The topography of the area suggested individual municipal permits
with respect to storm water conveyance identification would be overly complex with
possible jurisdictional disputes. Natural watercourses often leave one municipality,
enter the jurisdictional boundaries of a second or third municipality and re-enter a
portion of the first municipality. Individual municipal permits were not considered a
viable means of insuring control of storm water pollutants to the maximum extent
practicable. The St. Louis County urbanized area is complex from a jurisdictional
viewpoint.
The one plan and permit approach simplified the overall administration of the program
and avoided many of the problems associated with permits issued on the basis of
watersheds or the five MSD service areas. Each municipality is a co-permittee on one
permit regardless of service area location. Best management practices selected will be
applicable to all of St. Louis County and its municipalities. One storm water
management plan with one annual reporting obligation has been developed.
Cooperation is encouraged among all municipalities, regional authorities and state
agencies in the development, implementation and enforcement of the plan provisions.
Each co-permittee has been assigned responsibilities related to their obligation to
comply with the six Minimum Control Measures (MCM). For example, since the MSD
already has responsibility to operate and maintain the separate storm sewer systems in
the county, it has responsibility to comply with the requirements of MCM 3, Illicit
Discharge Detection and Elimination. St. Louis County and the municipalities with their
Phase II Plan Coordiantion
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land disturbance programs control pollution from land disturbance activities to comply
with the requirements of MCM 4, Construction Site Storm Water Runoff Control.
Because the MSD is the recognized continuing authority for sewer extensions within its
jurisdictional boundaries and has plan review responsibilities for storm water control, it
is responsible for best management practices in storm water facility design to comply
with MCM 5, Post Construction Storm Water Management in New Development and
Redevelopment. St. Louis County and the municipalities control the land use aspect of
MCM 5. All co-permittees are responsible for complying with requirements under MCM
6, Pollution Prevention/Good Housekeeping for Municipal Operations. Public
Education and Outreach (MCM 1) on storm water impacts and Public Involvement and
Participation (MCM 2) can best be coordinated by the MSD with municipal support
because of its various educational activities already in place and its policy to work with
community groups in cleaning up streams impacted by pollution discharges.
Eighty-nine municipalities exist in the Plan Area. Eighteen of the municipalities are
exempt from the Phase II Regulations because of populations less than 1,000. Twelve
additional St. Louis County municipalities within the Plan Area are exempt because of
combined sewer service. A complete list of municipalities within the Plan Area is
provided in Table 1.1. The location of a listed municipality can be determined by using
the “map reference number” included in the Table and the map of municipalities in
Figure 1.3. The co-permittee list will remain the same for the second permit term
because the census data has not been updated since the 2000 census.
E. Selection of a Coordinating Authority
Under its charter, MSD has been given the responsibility for providing adequate sewer
and drainage facilities within its boundaries. For the St. Louis County Plan Area, MSD
is the obvious agency of choice to coordinate compliance activities associated with the
Phase II Storm Water Regulations. However, the Phase II Regulations were specific in
naming cities that must be issued permits under the program and must meet certain
minimum control requirements related to municipal operations, e.g. vehicle
maintenance, salt storage and street sweeping. The MSD has been recognized as the
coordinating authority for development and implementation of the St. Louis Area Phase
II Storm Water Management Plan by St. Louis County municipalities and the Missouri
Department of Natural Resources.
F. Establishing a Planning Committee
The second St. Louis Municipalities Phase II Storm Water Planning Committee was
formed in December 2006 and held planning meetings once per month through June
2007 to evaluate best management practices, and make decisions regarding goals for
the second permit term. Membership of the committee is identified at the beginning of
this Plan (on page i), and includes a number of municipal representatives from small
and large cities, and representatives from local and state agencies.
Table 1.1 Land Area and Population of Municipalities in MSDs Service Area
Phase II Plan Coordiantion
1-8
MAP AREA** 2000 EXEMPTION
MUNICIPALITY
REF* TOT
AL BIS CWC LOM MOR RDP POP BASIS***
Ballwin 1 7.74 6.76 0.98 31283
Bella Villa 2 0.13 0.13 687 Population
Bellefontaine Neighbors 3 4.36 4.36 11271
Bellerive 4 0.34 0.34 254 Population
Bel-Nor 5 0.63 0.09 0.54 1598
Bel-Ridge 6 0.78 0.78 3082
Berkeley 7 4.96 1.73 3.23 10063
Beverly Hills 8 0.10 0.10 603 Comb Sewer
Black Jack 9 2.61 0.75 1.86 6792
Breckenridge Hills 10 0.80 0.80 4817
Brentwood 11 1.95 1.95 7693
Bridgeton 12 14.32 1.96 12.36 15550
Calverton Park 13 0.42 0.15 0.27 1322
Champ 14 0.80 0.80 12 Population
Charlack 15 0.27 0.27 1431
Chesterfield 16 32.21 0.03 32.18 46802
Clarkson Valley 17 2.73 0.02 2.71 2675
Clayton 18 2.51 2.51 12825
Cool Valley 19 0.46 0.46 1081
Country Club Hills 20 0.17 0.17 1381 Comb Sew
Country Life Acres 21 0.12 0.02 0.03 0.07 81 Population
Crestwood 22 3.58 3.58 11863
Creve Coeur 23 10.25 4.90 5.35 16500
Crystal Lake Park 24 0.10 0.10 457 Population
Dellwood 25 1.03 1.03 5255
Des Peres 26 4.29 2.75 1.54 8592
Edmundson 27 0.27 0.27 840 Population
Ellisville 28 4.19 3.23 0.96 9104
Fenton 30 6.35 6.35 4360
Ferguson 31 6.17 6.03 0.14 22406
Flordell Hills 32 0.12 0.12 931 Comb Sew
Florissant 33 11.42 0.20 10.39 0.83 50497
Frontenac 34 2.89 2.89 3483
Glendale 35 1.30 1.30 5767
Glen Echo Park 36 0.03 0.03 166 Population
Grantwood Village 37 0.81 0.81 883 Population
Greendale 38 0.19 0.19 722 Population
Green Park 39 1.31 1.31 2666
Hanley Hills 40 0.35 0.35 2124
Hazelwood 41 15.04 5.71 9.33 26206
Hillsdale 42 0.34 0.34 1477 Comb Sew
Huntleigh 43 0.98 0.98 323 Population
Jennings 44 3.77 3.77 15469
Kinloch 45 0.72 0.61 0.11 449 Population
Kirkwood 46 9.19 5.43 3.76 27324
* In Figure 1.2 from St. Louis County Department of Planning, Research and Statics Division
** Areas are in square miles
*** Municipalities exempt from Phase II requirements
Combined sewer systems, per 10 CSR 20-6.200(1)(C)16.C.
Populations less than 1000, per 10 CSR 20-6.200(1)(C)24A.
Phase II Plan Coordiantion
1-9
MAP AREA** 2000 EXEMPTION
MUNICIPALITY
REF* TOTAL BIS CWC LOM MOR RDP POP BASIS***
Ladue 47 8.55 8.55 8645
Lakeshire 48 0.21 0.21 1375
Mackenzie 49 0.02 0.02 137 Population
Manchester 50 5.00 5.00 19161
Maplewood 51 1.56 1.56 9228 Comb Sew
Marlborough 52 0.24 0.24 2235
Maryland Heights 53 22.09 22.09 25756
Moline Acres 54 0.57 0.57 2662
Normandy 55 1.86 1.52 0.34 5153
Northwoods 56 0.67 0.67 4643
Norwood Court 57 0.13 0.13 1061
Oakland 58 0.61 0.61 1540
Olivette 59 2.76 2.76 7438
Overland 60 4.40 0.19 1.76 0.05 2.40 16838
Pagedale 62 1.21 0.21 1.00 3616
Pasadena Hills 63 0.21 0.21 1147 Comb Sew
Pasadena Park 64 0.30 0.30 489 Population
Pine Lawn 65 0.61 0.61 4204 Comb Sewer
Richmond Heights 66 2.29 2.29 9602
Riverview 67 0.84 0.84 3146
Rock Hill 68 1.10 1.10 4765
St. Ann 69 3.15 2.73 0.42 13607
St. George 70 0.18 0.18 1288
St. John 71 1.43 1.03 0.39 0.01 6871
Shrewsbury 72 1.44 1.44 6644
Sunset Hills 73 9.04 7.83 1.21 8267
Sycamore Hills 74 0.13 0.10 0.03 722 Population
Town & Country 75 11.55 3.45 6.63 1.47 10894
Twin Oaks 76 0.26 0.26 362 Population
University City 77 5.88 5.88 37428 Comb Sew
Uplands Park 78 0.07 0.07 460 Comb Sew
Valley Park 79 3.16 3.16 6518
Velda city 80 0.17 0.17 1616 Comb Sew
Velda Village Hills 81 0.12 0.12 1090 Comb Sew
Vinita Park 82 0.73 0.06 0.67 1924
Vinita Terrace 83 0.06 0.06 292 Population
Warson Woods 84 0.57 0.57 1983
Webster Groves 85 5.89 5.89 23230
Wellston 86 0.93 0.31 0.62 2640 Comb Sew
Westwood 87 0.62 0.62 284 Population
Wilbur Park 88 0.06 0.06 475 Population
Wildwood 89 25.02 3.87 21.15 32884
Winchester 90 0.25 0.25 1651
Woodson Terrace 91 0.78 0.78 4189
St. Louis County, Unicp NA 158.54 26.43 26.08 71.01 9.99 25.03 326000
TOTALS 446.50 54.87 56.51 117.56 125.41 92.15
* In Figure 1.2 from St. Louis County Department of Planning, Research and Statics Division
** Areas are in square miles
*** Municipalities exempt from Phase II requirements
Combined sewer systems, per 10 CSR 20-6.200(1)(C)16.C.
Populations less than 1000, per 10 CSR 20-6.200(1)(C)24A.
Phase II Plan Coordiantion
1-10
G. Keeping the Community Informed
To keep the community informed of Planning Committee activities and progress being
made on developing this Plan, a monthly newsletter entitled the “Cloud Burst” was
published by the Metropolitan St. Louis Sewer District’s Division of Environmental
Compliance. The newsletter was mailed to municipal officials and provided to other
interested parties such as members of the East West Gateway Regional Water
Resources Advisory Council. The newsletters were also posted to MSD’s Phase II
Storm Water internet page.
The East-West Gateway Coordinating Council has established a Regional Water
Resources Advisory Council. The members of this Council represent a wide array of
experience and commitment to solving environmental problems in the St. Louis Region,
e.g. environmental advocacy groups, public officials, regulators, and community
planners. With representative members of the Council on the Planning Committee and
with two Phase II presentations provided, public input and participation was enabled in
the development of a Phase II Storm Water Management Plan for the Plan Area.
Also, public presentations and distribution of forms for public comment were provided at
the Earth Day symposium entitled, “Meeting of the Waters”. Presentations were
provided to two environmental groups that routinely participate in the activities of the
Phase II Storm Water program, the River des Peres Watershed Coalition and the Open
Space Council.
H. Plan Revisions
This Phase II Storm Water Management Plan is written for submittal with the co-
permittees’ MS4 permit application in September 2007. Regulatory circumstances may
change prior to the completion of this Plan in 2013. For example, if the Missouri 303(d)
list of impaired streams is revised, Special Conditions in permit section 3.1 would
become applicable. Also, once the 2010 census is taken, additional cities may need to
be permitted and some cities may elect to terminate permit coverage. The new cities
would need to be included in the Plan and goals established for them to implement the
storm water management program. In both cases, MSD as the coordinating authority
would need to consult with the MDNR, and revise the Phase II Storm Water
Management Plan accordingly.
Demographics of the St. Louis Area
2-1
CHAPTER 2
Demographics of the St. Louis Area
A new tool is now available from the East West Gateway Council of Governments
regarding demographics in the St. Louis Area that was not presented in the first Storm
Water Management Plan. The Gateway Blueprint Model was developed in a
partnership between the East-West Gateway Council of Governments and researchers
at the University of Illinois Urbana-Champaign. The model makes use of land use
forecasting methodology known as the Land Use Evolution and Assessment Model
(LEAM). LEAM forecasts the probability of land use change for each quarter-acre patch
of land in the region. There are about 20 million of these quarter-acre “cells” in the St.
Louis region.
In LEAM, the probability of land use change for a given cell is a function of a variety of
factors such as the availability of developable land, proximity to an interstate
interchange, proximity to major intersections and proximity to employment centers. The
Gateway Blueprint Model was developed by empirically deriving the statistical
relationships between the “drivers” of land use change and observed patterns of
development in the St. Louis region.
It is important to note that the Blueprint Model forecast is not a prediction of the future.
Rather, the model shows likely outcomes associated with current policies relevant to
land use, including foreseeable changes in the transportation system. The forecast
information from this model will be relevant for co-permittees’ planning and zoning
authorities as they evaluate changes in their ordinances and policies, and consider the
potential impact on water quality from land use changes.
Figure 2.1 shows areas of new residential and commercial development between 2007
and 2040, as forecast by the Gateway Blueprint Model. Red patches indicate new
commercial development, while yellow shows new residential development. The areas
most likely to see new development are in various areas throughout the plan area, but
mainly in the west and southern portions of the area.
This forecast is broadly consistent with population forecasts prepared independently by
the East-West Gateway Council of Governments. Figure 2.2 shows areas expected to
experience increases in population between 2007 and 2040. As with the Gateway
Blueprint forecast, high growth rates are expected in: Ballwin, Chesterfield, Creve
Coeur, Ellisville, Fenton, Hazelwood, Manchester, Norwood Court, Sunset Hills, and
Valley Park.
Demographics of the St. Louis Area
Figure 2.1 New Residential and Commercial Development Forecast
The new development forecasts from the Gateway Blueprint Model were overlaid with
current parcels of undeveloped, commercial and vacant land to show areas likely to
experience loss of open space in coming decades. Table 2.1 shows the acres of
undeveloped land considered to be likely sites for residential and commercial
development:
Table 2.1: Population and Land Use Change Forecasts, 2007-2035
Growth Area Population Growth New Residential New Commercial
Wildwood 10,000 1,848 acres 137 acres
Chesterfield <500* 953 acres 53 acres
Sunset Hills 2,700 683 acres 138 acres
South St. Louis Co. 13,000 2,037 acres 219 acres
North St. Louis Co. 12,000 966 acres 64 acres
* The Model predicts new development in the western portion of the city, which is offset
by population loss in the southeast portion of the city.
Source: East-West Gateway Council of Governments, Gateway Blueprint Model
Figure 2.2 Municipal Population Growth Forecast
2-2
Demographics of the St. Louis Area
The region’s urban form is changing as the population sprawls outward from the urban
core. The map in figure 2.3 shows how the urbanized area has expanded since 1950.
The rate of land consumption has far outpaced the rate of population growth. According
to US Census Bureau data compiled by East West Gateway, the urbanized area has
grown by 286 percent between 1950 and 2000, while the population grew by only 40%.
This has resulted in much lower density in recent development than in established
urbanized areas previously developed. Despite the lower density development, the
Plan Area is largely built out, and water quality has still been impacted, as discussed in
the next chapter.
2-3
Demographics of the St. Louis Area
Figure 2.3 Change in Urbanized Areas
2-4
Water Quality in St. Louis County Streams
3-1
CHAPTER 3
Water Quality in St. Louis County Streams
A. Missouri Water Quality Standards
The water quality standards for Missouri waters are set forth in Missouri regulation 10
CSR 20-7.031. This regulation identifies various general categories of waters;
establishes classifications and designates beneficial uses for some waters; establishes
general water quality standards that must be met for all waters; and establishes specific
water quality criteria that must be met for classified waters. The general categories of
waters identified in the regulation include:
• Metropolitan No-Discharge
• Outstanding National Resource Waters
• Outstanding State Resource Waters
• Losing Streams
• Classified Streams and Classified Lakes
• Unclassified Streams and Unclassified Lakes
• Groundwater
There is overlap among these categories with some water bodies falling into more than
one category. Except for Outstanding National and State Resource Waters, all of these
categories are represented within the St. Louis County Plan Area. Unclassified lakes
and streams make up the majority of water bodies in the Plan Area. Table 3.1 lists
streams and lakes in the Plan Area and identifies the applicable category and
classification information from the Missouri Water Quality Standards.
Section (3) of the regulation lists general criteria, which apply to all waters of the state at
all times. These general criteria are referenced in Section 4.1.1.1 of Missouri’s Small-
MS4 permit as follows:
The discharge of storm water shall not cause a violation of the state water
quality standards, 10 CSR 20-7.031, which states, in part, that no water
contaminant, by itself or in combination with other substances, shall
prevent the waters of the state from meeting the following conditions:
a. Waters shall be free from substances in sufficient amounts to cause
the formation of putrescent, unsightly or harmful bottom deposits or
prevent full maintenance of beneficial uses;
b. Waters shall be free from oil, scum and floating debris in sufficient
amounts to be unsightly or prevent full maintenance of beneficial uses;
Water Quality in St. Louis County Streams
c. Waters shall be free from substances in sufficient amounts to cause
unsightly color or turbidity, offensive odor or prevent full maintenance of
beneficial uses;
d. Waters shall be free from substances or conditions in sufficient
amounts to result in toxicity to human, animal or aquatic life;
e. There shall be no significant human health hazard from incidental
contact with the water;
f. There shall be no acute toxicity to livestock or wildlife watering;
g. Waters shall be free from physical, chemical or hydrologic changes that
would impair the natural biological community;
h. Waters shall be free from used tires, car bodies, appliances, demolition
debris, used vehicles or equipment and solid waste as defined in
Missouri’s Solid waste Law, section 260.200, RSMo, except as the use of
such materials is specifically permitted pursuant to section 260.200-
260.247.
Section (4) of the regulation establishes specific criteria for all classified waters of the
state based on the designated uses for those waters.
Storm water permittee compliance with the Missouri Water Quality Standards is
mandated in Section (5)(A) of Missouri’s storm water regulation (10 CSR 20-6.200).
This section states, in part:
Applicants for permits for discharges from small MS4s must develop and
submit descriptions of storm water management programs designed to
reduce pollutants in storm water runoff to protect water quality of receiving
waters.
Subsequent sections of this Plan describe how the co-permittees will protect the quality
of storm water runoff within the Plan Area.
3-2
Water Quality in St. Louis County Streams
3-3
Table 3.1 Water Bodies in the St. Louis County Phase II Plan Area
That are Listed in the Missouri Water Quality Standards (10 CSR 20-7.031 as amended 12/31/05)
Location Classification2 Designated Beneficial Uses3 Metro
ND4 Losing5 MSD SA
Water Body1 Mouth or Start of
Segment Class Length IR LW AQ CF WB BT DW IN Length Length
Mississippi River Ohio River P 195.5 ° ° ° ° ° ° 6
Mississippi River Dam #27 P 5.0 ° ° ° B ° ° ° 6
Meramec River SW,NW,10,42N,6E P 22.0 ° ° A ° ° ° LOM
Meramec River Hwy 141 P 26.0 ° ° ° A ° ° ° LOM
Bee Tree Lake NW,NE,3,42N,6E L3 9 ac ° ° B ° LOM
Mattese Creek NE,NW,22,43N,6E P 0.9 ° ° B LOM
Fenton Creek 35,43N,05E P 0.5 ° ° B LOM
Grand Glaize Creek SW,NE,16,44N,5E C 4.0 ° ° B All LOM
Fishpot Creek SE,SE,18,44N,5E P 2.0 ° ° B All LOM
Fishpot Creek 13,44N,4E 5.0 LOM
Un-named Tributary NW,NW,NW,13,44N,4E 2.0 LOM
Williams Creek SE,SE,13,44N,4E P 1.0 ° ° B LOM
Kiefer Creek SE,SE,14,44N,4E P 0.5 ° ° B LOM
Kiefer Creek NW,SE,SE,14,44N,4E 3.0 LOM
Un-named Tributary NW,SW,NE,9,44N,4E 1.0 LOM
Hamilton Creek7 14,44N,3E 0.5 LOM
Un-named Tributary7 SE,SE,NE,14,44N,3E 1.0 LOM
Antire Creek SE,SE,32,44N,4E P 1.5 ° ° B 0.2 LOM
Un-named Tributary NW,NW,SE,24,43N,6E LOM
River des Peres NE,SW,20,44N,7E P 1.5 ° ° RDP
River des Peres NW,SE,17,44N,6E C 1.0 ° ° RDP
Gravois Creek NW,SE,17,44N,6E P 2.0 ° ° B All RDP
Gravois Creek 24,44N,6E C 4.0 ° ° B RDP
Maline Creek SE,NW,15,46N,7E C 1.0 ° ° BIS
Watkins Creek SW,NE,36,47N,7E C 3.5 ° ° B BIS
Missouri River 47N,8E P 100 ° ° ° B ° ° ° 6
Sunfish Lake 23,47N,7E L3 34 ° ° B ° BIS
Coldwater Creek SW,NW,10,47N,7E C 5.5 ° ° B ° All CWC
Fee Fee Creek (old) SE,SE,29,46N,5E P 1.0 ° ° B MOR
Creve Coeur Creek
(Below lake) NE,NE,7,46N,5E P 3.0 ° ° B MOR
Fee Fee Creek (new) SW,SW,8,46N,5E P 1.5 ° ° B All MOR
-Creve Coeur Lake 20,46N,5E L3 300 ac ° ° B ° All MOR
-Creve Coeur Creek
(Above lake) SW,SW,20,46N,5E C 2.0 ° ° B All MOR
Bonhomme Creek NW,NE,4,45N,4E C 2.0 ° ° B MOR
Bonhomme Creek 8 SE,SW,NE,2,44N,3E 0.7 MOR
Caulks Creek NE,NE,SW,31,45N,4E 0.5 MOR
Caulks Creek NE,SE,SE,13,45N,3E 3.0 MOR
Un-named Tributary NW,SE,SW,30,45N,4E 1.0 MOR
1 Water Bodies are arranged in ascending order from the lowest point in the Plan Area. An indented water body is tributary to the one above it.
All stream lengths are in miles. 2 Classified Waters Classifications:
L3 Private and public lakes other than major reservoirs and other than lakes used primarily for water supply.
P Streams that maintain permanent flow even in drought periods.
C Streams that may cease flow in dry periods but maintain permanent pools that support aquatic life. 3 Beneficial Uses:
IR = Irrigation; LW = Livestock & wildlife watering; AQ = Protection of warm water aquatic life and human health--fish consumption;
CF = Cool water fishery; WB = Whole body contact recreation (class A or B); BT = Boating & canoeing; DW = Drinking water supply;
4 Metropolitan No-Discharge Streams:
IN = Industry.
These streams may only receive uncontaminated cooling water, permitted storm water discharges and wet weather bypasses that do not
interfere with beneficial uses. The no-discharge condition applies to the entire watershed of the stream, including all tributaries.
5 Losing Streams: Streams that lose a significant portion of their flow during low-flow conditions via permeable geologic materials into aquifers.
7 The main stem of Hamilton Creek is outside the Plan Area. However, the upper reach of the losing tributary is within the Plan Area.
6 Parts of the Mississippi River are included in the BIS, RDP and LOM service areas. Parts of the Missouri River, in the BIS, CWC and MOR. 8 The losing upper reach of Bonhomme Creek is outside the Plan Area. However, parts of the Plan Area drain to this reach.
3-4
B. Impaired Waters
Section 303(d) of the federal Clean Water Act requires states to identify water bodies
that cannot meet water quality standards after applying the existing regulations. For
waters on this list (impaired waters), a plan must be developed to fix the problem.
Such plans will include a Total Maximum Daily Load (TMDL) calculation of the
maximum amount of a pollutant a water body can absorb without being impaired.
Section 3.1 of Missouri’s Small-MS4 permit imposes additional requirements on
permittees who have discharges which “significantly” contribute to 303(d) water bodies.
This section requires a permittee, having storm water discharges upstream from an
impaired water body, to determine whether those discharges are significantly
contributing directly or indirectly to the impaired water body and to further identify any
TMDL approved for that water body. If the permittee determines that it is significantly
contributing to the impaired water body, the permittee must include, within its storm
water management plan, steps to control the pollutants of concern and to ensure that
the permittee’s discharges do not cause or contribute to instream exceedances of the
water quality standards. If a TMDL has been approved the permittee must include
provisions within its program to ensure that all requirements of the TMDL will be met.
Grand Glaize Creek is the only stream, located within the Plan Area, that is listed on
Missouri’s 2002 303(d) list. It is listed based on the levels of mercury in fish tissue. As
a result of this listing and the Missouri fish consumption advisories, mercury is a
pollutant of concern under this Plan. The main source of the mercury has been
identified as atmospheric deposition. It should be noted that Grand Glaize Creek is not
unique in exhibiting a mercury problem. Increasing mercury levels have been found in
fish statewide and the Missouri Department of Health and Senior Services currently has
an advisory against consumption of certain fish from all Missouri waters due to mercury
contamination. In Missouri’s 2004/2006 proposed 303(d) list, the mercury impairment
on Grand Glaize Creek is proposed to be removed.
Early in 2007, MDNR’s 2004/2006 Proposed Missouri 303(d) list contained seven
streams listed as impaired for chloride and/or bacteria. As discussed in the Permit
Year 3 Annual Report and regardless of final actions on the list, the proposed listing
was deemed significant enough to identify chloride as an additional pollutant of
particular concern under this Plan. Bacteria was previously identified as a pollutant of
concern in the 2002 Plan. To date, no TMDLs have been developed for any pollutants
in the Plan Area.
C. USGS Water Quality Monitoring
Since 1996, the MSD has had a joint funding agreement with the U.S. Department of
the Interior U.S. Geological Survey (USGS) for water resources investigations in St.
Louis County. Under past agreements, the USGS monitored 35 stream gauging
stations of which 20 were also water quality stations within the county portion of the
MSD service area. The locations of these stations are shown in Figure 3.1. Flow data
are retrieved monthly from the gauging stations. Since 2005, only five water quality
Water Quality in St. Louis County Streams
stations have been funded by MSD to represent each of MSD’s five watershed service
areas. The streams (and USGS site number) are: Coldwater Creek (06936475), Creve
Coeur Creek (06935890), Grand Glaize Creek (07019185), Maline Creek (07005000),
and River des Peres (07010022). Water quality samples are collected four times per
year from the water quality stations during base flow conditions and twice per year for
rainfall events occurring in the spring and fall. Only wet weather samples were
evaluated in the data comparison to represent water quality and identify pollutants in
storm water runoff, rather than including dry weather samples that represent ambient
stream water quality. Rainfall event sampling occurs during the first flush flow condition
in the stream. Data, for the period 1997 through 2005, are available for storm event
sampling at 17 of these stations, and recent data are shown in Appendix A3-1. The
intent of this sampling was to gather baseline data to be used for a variety of purposes,
one of which was to evaluate progress under the Phase II Storm Water Regulations.
Evaluation of the data for this purpose will be discussed below.
D. Identification of Area Storm Water Pollution Problems/Sources
The data resulting from the USGS sampling efforts and MDNR’s 303(d) listing process
described above were reviewed to identify specific concerns that would need to be
addressed in the implementation of the Phase II Storm Water Management Plan. Table
3.2 provides a simple comparison of the pollutant levels detected during wet weather
sampling events versus the level listed for the pollutant in the water quality standards.
The analysis does not attempt to duplicate the detailed methodology and 303(d) listing
process conducted by MDNR under the water quality regulations.
3-5
Water Quality in St. Louis County Streams
Figure 3.1 Sampling Stations
3-6
Water Quality in St. Louis County Streams
Table 3.2 Water Quality Analysis for the St. Louis County Phase II Plan Area During Storm Events
USGS Sampling Results (All Samples) USGS Sampling Results (Since 2003)
Exceeds Level in WQS Exceeds Level in WQS
Acute Chronic Acute Chronic
PARAMETER Total
Samples No. % No. %
Total
Samples No. % No. %
pH **
Temperature **
Dissolved Oxygen 235 7 3.0 63 0 0.0
Fecal Coliform 183 183 100.0 52 52 100.0
Fecal Streptococci *
Total Nitrogen as N *
Total Kjeldahl Nitrogen as N *
Ammonia as N 230 0 0.0 2 0.9 64 0 0.0
Total Phosphorous as P *
Total Phosphate as PO4 *
Hardness as CaCO3 *
Chemical Oxygen Demand *
Total Dissolved Solids *
Total Suspended Solids *
Oil and Grease 154 5 3.2 54 3 5.6
Chloride 1 0 0.0 0 0.0
Aluminum, dissolved 233 22 9.4 64 2 3.1
Arsenic, dissolved 234 0 0.0 64 0 0.0
Beryllium, dissolved 233 0 0.0 64 0 0.0
Cadmium, dissolved 234 0 0.0 12 5.1 64 0 0.0 0 0.0
Chromium, dissolved 234 0 0.0 0 0.0 64 0 0.0 0 0.0
Copper, dissolved 234 1 0.4 10 4.2 64 0 0.0 0 0.0
Iron, dissolved 234 14 6.0 64 2 3.1
Lead, dissolved 234 1 0.4 28 12.0 64 0 0.0 2 3.1
Manganese, dissolved **
Mercury, total recoverable 234 0 0.0 1 0.4 64 0 0.0 0 0.0
Nickel, dissolved 234 0 0.0 0 0.0 64 0 0.0 0 0.0
Selenium, dissolved 234 0 0.0 64 0 0.0
Silver, dissolved 234 0 0.0 64 0 0.0
Zinc, dissolved 234 9 3.8 15 6.4 64 0 0.0 0 0.0
KEY: USGS Results are for samples collected during the first-flush flow condition in the stream.
* - Samples are typically also analyzed for these parameters. If the acute or chronic columns are empty for a
parameter, for which samples have been collected, it means Missouri has no relevant acute and/or chronic Water
Quality Standard for that parameter.
Individual sample results are contained in Appendix A3-1.
The compliance status for some key pollutants is discussed in the following paragraphs.
1. Wet Weather Flow Water Quality
The water quality analysis of data in Table 3.2 shows the number of samples from wet
weather stream sampling that contain levels of pollutants above the comparable level
listed in the water quality standards. With the exception of lead and fecal coliform, all
the parameters analyzed were less than the level in the water quality criteria over 90%
of the time. The exceedances occurred at widely scattered locations and times,
indicating that they are isolated events unrelated to a specific source. However, lead
and fecal coliform exceeded the level in the water quality criteria 12 percent and 100
percent of the time, respectively.
3-7
Water Quality in St. Louis County Streams
Twenty-eight of the samples contained lead over the criterion in the water quality
standards. However, seventy-five percent of these samples came from Fishpot, Kiefer,
and River des Peres watersheds during the period of 1999 through 2001. These
watersheds were compared to more stringent criteria than the other streams since they
have lower average hardness than other streams in the area. Water quality criteria for
lead are hardness dependent, therefore, the low hardness results in a lower numeric
criteria. Since 2002, only two of the samples contained elevated lead, therefore,
specifically targeting lead as a pollutant of concern under this Plan is not deemed
warranted at this time.
Fecal coliform exceeded the criterion in the water quality standards one hundred
percent of the time. The level of fecal coliform bacteria is elevated in all twenty of the
sampled watersheds and during all periods of wet weather sampling. Therefore, fecal
coliform is identified as a pollutant of particular concern under this Plan.
While the bulk of the data, described above, shows a high level of compliance with the
water quality standards during storm events, the previous discussion as well as visual
observations of streams and land areas indicate there is a need for emphasis on
addressing certain water quality concerns in the Plan Area. These concerns include:
• Elevated levels of Suspended Solids;
• Elevated levels of Fecal Coliform;
• Elevated levels of Chloride;
• Floating Debris/Trash;
• Mercury in Fish Tissue;
This plan includes Best Management Practices (BMPs) to address all potential sources
of pollutants in storm water as required by the federal and state regulations. Additional
emphasis was placed on identifying BMPs which address the major problems identified
above. Following is a discussion of each of the major pollutants of concern.
2. Suspended Solids
The Missouri Water Quality Standards do not contain numerical criterion for suspended
solids. However, the general criteria, as enumerated above, require that waters be free
from substances that cause unsightly or harmful bottom deposits, unsightly color or
turbidity or prevent full maintenance of uses. Suspended solids in excessive amounts
can contribute to all of these water quality problems. A particular cause is sediment
discharged from land areas disturbed by construction activities including but not limited
to subdivisions, shopping centers, and road projects. Excessive stream velocities
influenced by impervious areas can erode stream banks and beds adding to suspended
solids.
The USGS storm event sampling data includes results of Total Suspended Solids (TSS)
analyses. As previously noted, the USGS sampling effort involves base flow sampling
as well as storm event sampling. Base flow TSS levels are generally in the single to low
double digit figures while storm event (first flush) results range from ten to two-hundred
3-8
Water Quality in St. Louis County Streams
times the base flow levels. The results show considerable variation in TSS levels from
storm to storm at the same station. There is no apparent, direct correlation based on
stream flows or storm intensity at the time of sampling.
Field observations of streams after storm events have noted deposition of sediments
downstream from land disturbance sites. Runoff from the highly developed, and
therefore more impervious county areas, coupled with stream channelization in those
areas also promotes greater erosion of stream banks, which contributes to elevated
solids levels.
Land disturbance site problems have been addressed through enactment of appropriate
ordinances in implementing MCM 4 requirements as described in the 2002 Plan with
adequate enforcement and through increased public education as discussed in other
sections of this Plan. In comparing overall average TSS concentrations at the 17 water
quality stations with data since 2003, the area streams recently had lower TSS levels
overall as 12 of the streams had lower concentrations, two about the same and three
had higher TSS concentrations. However, ten of the streams with lower concentrations
of TSS also had lower average stream flow, which may broadly account for the
reduction in TSS.
3. Fecal Coliform
The Missouri Water Quality Standards currently set a fecal coliform criterion of 200
colonies/100 mL during the recreational season (April - October) for streams and lakes
designated for class A whole body contact recreational use. The Water Quality
Standards also recently added E. coli bacteria criteria of 126 colonies/100 mL for class
A whole body contact recreational use and 548 colonies/100 mL for class B whole body
contact recreational use. Since the E. coli criteria are new, past data analysis did not
evaluate this pollutant. Except for the Meramec River, no water bodies in St. Louis
County currently are classified for class A whole body contact recreation. Nearly all the
other water bodies are classified for class B whole body contact recreation, for which a
fecal coliform standard does not exist.
EPA’s Nationwide Urban Runoff Program (NURP) study found high levels of fecal
coliform in urban runoff and concluded that levels can be expected to exceed water
quality criteria during and immediately after storm events in many surface waters, even
those providing high degrees of dilution. As shown in Appendices A3-1, fecal coliform
levels, at the St. Louis County sampling stations, during periods of storm water runoff
typically exceed the recreational-use standard by several orders of magnitude. Other
studies have reported that primary sources of pathogens in urban storm water runoff are
animal wastes (including pets), failing septic systems, illicit sewage connections and
marine wastes. In recent years, the increasing use of DNA technology to identify
specific sources appears to be strengthening the case for animal wastes being a more
significant source of fecal coliform than previously thought. A review of the data
indicates that a significant source of fecal coliform in the Plan Area streams is animal
wastes.
3-9
Water Quality in St. Louis County Streams
As stated in EPA’s BMP guidance information on pet waste collection for municipal
operations, “According to recent research, nonhuman waste represents a significant
source of bacterial contamination in urban watersheds. Genetic studies by Alderiso et
al. (1996) and Trial et al. (1993) both concluded that 95% of fecal coliform found in
urban storm water were of nonhuman origin.”
The increasing evidence that wild and domestic animals are significant contributors to
high levels of fecal coliform in storm water runoff adds to the difficulty of reducing this
pollutant in water bodies. Fecal coliform from wild animals is somewhat beyond local
governments’ ability to control. On the other hand, BMPs that can be effective in
reducing fecal coliform from domesticated animals, particularly household pets, can be
instituted. Such BMPs typically include appropriate enforceable ordinances such as
those listed in the model Operation and Maintenance program document (available on
the MSD website) to comply with MCM 6 and public education as discussed in other
sections of this Plan. With regard to reducing fecal coliform from human sources, MSD
is working on a multiple decade, multiple billion dollar capital improvement program to
improve the area’s sanitary collection system in addition to implementing BMPs to
address illicit discharges.
4. Chloride
The Missouri Water Quality Standards currently set a chloride chronic criterion of 230
mg/L for streams and lakes designated for protection of aquatic life. MDNR’s analysis
of the chloride concentrations for the 2004/2006 Proposed Missouri 303(d) list provided
evidence for some level of concern regarding this nonpoint source pollutant.
Significant contributions of chloride to the water bodies is expected to be from snow and
ice removal through the use of salt application on roads, parking lots and driveways.
The higher chloride values observed during the winter months supports this conclusion.
BMPs implemented under this Plan in Chapters 4 and 9 will increase awareness among
co-permittees and the public about this problem.
5. Trash
One of the general criteria in the Missouri Water Quality Standards requires waters to
be free from floating debris in sufficient amounts to be unsightly or prevent full
maintenance of beneficial uses. Items discarded in or near streams can consist of
anything from simple waste paper and plastics to used oil filters and toxic chemicals.
Trash, discarded in a stream, can contribute to violations of any of the general criteria
enumerated earlier.
Trash has been identified as a significant problem based on direct observations of
streams, roadsides, and other areas including: residential, industrial, and commercial
sites. Roadside litter and overflowing trash containers have been observed in many
areas of the county. Trash containers at industrial and commercial sites are often either
undersized or are not emptied frequently enough. Employees of such establishments,
when faced with this situation, typically leave the lids open and stack additional trash
well above the sides of the container or simply pile it on the ground next to the full
3-10
Water Quality in St. Louis County Streams
container. Much of this material ends up scattered about the landscape and is
eventually blown or washed into nearby streams. It is not uncommon to see debris,
from these and other sources, caught up in the branches of stream bank vegetation,
carried in storm-swollen streams, or heaped in stream channels after storm-induced
flows have subsided. These problems are being addressed through enactment of
appropriate ordinances such as those listed in the model Operation and Maintenance
program document to comply with MCM 6, with adequate enforcement and through
increased public education and involvement as discussed in Chapter 4 and 5 of this
Plan.
6. Mercury
Mercury has been identified as a pollutant of concern under the Plan due to Missouri
health advisories on fish consumption as a result of the high levels of mercury found in
fish tissue. Despite the main source of mercury in fish tissue identified as resulting from
atmospheric depostition, other sources of mercury in the environment result from
mercury containing products that are improperly disposed. These products include
household hazardous waste and electronic devices, which will be addressed along with
the public education and public participation efforts related to trash.
3-11
Water Quality in St. Louis County Streams
3-12
Public Education And Outreach
4-1
CHAPTER 4
Public Education and Outreach (MCM 1)
A. MS4 Permit Requirements
Section 4.2.1.1 of the general MS4 permit requires the permittee to implement a public
education program to distribute educational materials to the community or conduct
equivalent outreach activities about the impacts of storm water discharges on water
bodies and the steps that the public can take to reduce pollutants in storm water runoff.
Section 4.2.1.2 of the permit requires inclusion of the following elements in this
program:
Plans to inform individuals and households about the steps they can
take to reduce storm water pollution;
Plans to inform individuals and groups on how to become involved
in the storm water program (with activities such as local stream and
beach restoration activities);
Identification of target audiences who are likely to have significant
storm water impacts (including commercial, industrial and
institutional entities);
Identification of the target pollutant sources the program is designed
to address; and
An outreach strategy, including the mechanisms (e.g., printed
brochures, newspapers, media, workshops, etc.) that will be used to
reach the target audiences and the number of people this strategy is
expected to reach.
B. General Pollution Prevention Compliance Activities
The Metropolitan St. Louis Sewer District will have the overall responsibility for
coordinating the public education and outreach efforts described in this Plan. Programs
will include, but are not limited to, the distribution of educational materials and
promotion of outreach activities. Programs will be implemented throughout the Plan
Area to the maximum extent practicable using a variety of approaches, and will consider
the various needs of the community.
Depending on the type of pollution contained in storm water runoff, the impact on
natural watercourses can be cumulatively severe. It is readily recognized that runoff
pollution is the major cause of water quality problems in most urban watersheds. It
must also be recognized that each individual is personally responsible for the pollutants
Public Education And Outreach
in the runoff from his or her occupied land area. It is obvious that we can never meet
our water quality goals for streams and lakes until we convince owners and land users
to change behaviors and become better watershed stewards. Ordinary citizens must
also be conscious of their responsibility for proper handling of trash, pet wastes, and
other sources of pollution wherever they are located.
The basic implementation approach will be to seek out and form partnerships with
municipalities, civic organizations, educational institutions and businesses to assure the
water quality needs of the community are met. Education and information will address
general pollution prevention goals plus specific pollution problems identified through
previous field investigations as having a significant impact on Plan Area water quality,
i.e., trash, animal waste, soil solids, chloride, and mercury. Where possible, the
program design will utilize and promote the use of educational materials found to be
effective previously or by other metropolitan areas, states, or organizations.
Educational materials will offer options and alternatives for prevention and proper
disposal of pollutants that could be discharged in storm water. Emphasis will be given
to the economic importance and community benefits of pollution prevention, proper
waste disposal, and resource management activities.
C. Compliance Activities using Printed Material
MSD has developed, printed, and distributed nine different brochures dealing with
various topics, and continues to distribute various brochures, fact sheets and booklets
on an ongoing basis using established outlets.
D. Compliance Activities using Presentations
MSD presents storm water quality educational information to grade school classrooms,
plus various industry and community groups. Most of the classroom presentations
involve the presentation of a nonpoint source pollution model. Booths at public events
are another method MSD uses to present information to the public.
E. Compliance Activities using Other Media
MSD continues to support the airing of the pollution prevention videos developed under
the first plan on Charter cable. Video media will continue to be developed and aired.
MSD will continue to maintain its internet Phase II web page.
The programs’ distribution process will utilize several approaches to reach target
audiences. A variety of mechanisms will continue to be used to deliver programs
throughout the Plan Area, including websites, fact sheets, newsletters, utility bill inserts,
speakers bureaus, brochures, school curricula, and seminars.
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Public Education And Outreach
F. Rationale for New Goals
Annual progress reports will be provided to document compliance with established
goals and, for new initiatives, the specific activities associated with each year have been
defined along with selected measurements as defined below. A successful outreach
effort has been implemented as described in the 2002 Plan. MSD intends to continue
the effective program efforts. Note that in addition to the efforts listed under MCM 1,
MSD will undertake many educational efforts as part of the other control measures, as
described elsewhere in this Plan.
MSD’s experience and public comments indicate that MSD’s efforts alone will not be the
most effective at educating the public. MSD must use community and agency
partnerships more effectively. In addition, to take advantage of the large amount of
existing communication by the co-permittees and partners on various topics, a
consistent message is needed to provide the connection of various waste issues with
water quality impacts. A committee approach will be used to further improve the public
education program.
Annually
MSD will report the number of brochures and other educational materials distributed.
MSD will report the number of presentations given.
MSD will report the number of Phase II web page visits.
Year 1
MSD will form a local or regional committee to develop an outreach strategy and
implement a communication plan for water quality public education. The committee will
include involvement from a number of co-permittees and partners from agencies,
community groups, and others. A consistent message will be promoted over a variety
of formats, such as municipal newsletters, partner newsletters, web pages, listserves,
and media contacts. One product could be to write example newsletter articles to
promote its publication by co-permittees and partners.
Year 2
MSD will develop a radio public service announcement and distribute to radio stations
for Phase II messages; for example, salt use on driveways and parking lots, pet waste,
yard waste, or watershed awareness.
4-3
Public Education And Outreach
Year 3
MSD will distribute educational materials on a relevant topic throughout the District
using bill inserts (distributed to all customers) or cable (distributed to all subscribing
households) or other mass media.
Year 4
MSD will distribute educational materials on a relevant topic throughout the District
using bill inserts (distributed to all customers) or cable (distributed to all subscribing
households) or other mass media.
Year 5
MSD will distribute educational materials on a relevant topic throughout the District
using bill inserts (distributed to all customers) or cable (distributed to all subscribing
households) or other mass media.
To test the public’s knowledge of storm water issues a questionnaire will be developed
and a telephone survey conducted. The information will be used to analyze the impact
of MSD’s educational activities on making the public more aware of storm water quality
issues and needs. Effective actions will be continued but subject matter may be revised
and expanded.
4-4
Public Involvement and Participation
5-1
CHAPTER 5
Public Involvement and Participation (MCM 2)
A. MS4 Permit Requirements
Section 4.2.2.1 of the general MS4 permit requires the permittee to implement a public
involvement/participation program that complies with State and local public notice
requirements.
Section 4.2.2.2 of the permit requires inclusion of the following elements in this
program:
Involvement of the public in the development and submittal of the
permit application and storm water management program;
Plans to actively involve the public in the development and
implementation of the public involvement/participation program;
Identification of the target audiences, including the types of ethnic
and economic groups engaged;
Identification of the types of public involvement activities to be
included with the following mandatory (where appropriate):
• Citizen representatives on a storm water management panel
• Public hearings
• Working with citizen volunteers willing to educate others about the
program
• Volunteer monitoring or stream/beach clean-up activities
B. Public Involvement in Storm Water Plan Development
As part of the Phase II Storm Water Management Planning process, MSD, on behalf of
the Planning Committee, presented, on several occasions at public venues, the
accomplishments of the Plan implementation and the proposed goals for the 2007 plan.
Requests were made for comments and discussion. Many comments were considered
and the proposed plans improved as a result.
For ongoing public involvement, the Metropolitan St. Louis Sewer District has the overall
responsibility for coordination of the public participation and involvement activities
described in this Plan. The St. Louis Metropolitan area benefits from a number of
different environmental groups, stream teams, and other organizations concerned with
various aspects of environmental protection. Under the 2002 Plan, efforts to
Public Involvement and Participation
consolidate these groups into a new organization were not successful in serving the
diverse interests of the many groups. Rather than duplicating and competing with
existing membership organizations, MSD participates in a number of public
environmental initiatives, involving watershed coalitions, partnerships, etc., upon
request. These groups assist in promoting public awareness and serve as volunteers to
participate in activities to reduce the impact of storm water pollution in the Plan Area.
As part of managing the storm water system, MSD utilizes a Rate Commission for
addressing issues involving rates, and holds a number of public meetings, and through
strategic planning initiatives, implements a Community Outreach program and builds
relationships with stakeholders.
C. Public Participation Programs
Citizens are encouraged to partner with MSD on a number of programs to educate the
community or participate in clean-up projects to remove trash from area streams. The
programs include:
Storm Drain Marking Program – This educational program involves working with groups
to install four inch diameter plastic markers on storm drain inlets with the message, “No
Dumping, Drains to Stream”. This is an ongoing communication at the source of
discharge informing the public not to use storm drains for dumping waste. Educational
outreach extends further when the groups use door hangers, as instructed, explaining
the purpose of the markers to the community.
Stream Clean-ups – MSD partners with community groups in being an enabler to help
them accomplish a successful stream clean-up effort. Depending on the group involved
and the need, MSD has provided: trash disposal, glove and bag supplies, flyer printing,
press release, volunteer labor, paid labor, and heavy equipment, such as trucks and
tractors.
Nonpoint Source Pollution Education – A network of teachers and community group
leaders help MSD educate the public on nonpoint source pollution. The main vehicle
used is a nonpoint source pollution model with script provided by MSD.
Household Hazardous Waste Collection – St. Louis County Department of Health is
responsible for engaging the public in participating in household hazardous waste &
recyclables collection days. St. Louis County is developing a permanent dropoff
program for household hazardous waste, evolving the program from periodic one-day
events to permanent, fixed dropoff locations.
D. Pet Owner Responsibilities
Fecal coliform levels in Plan Area watercourses have been found to be elevated, and
animal sources contribute significantly. Groups that include pet owners, pet stores,
veterinarians, humane societies, and members of the community were asked to help
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Public Involvement and Participation
address pet waste management, and continue ongoing distribution of public educational
materials. Communities have addressed pet owner responsibilities in the development
of ordinances or other enforcement mechanisms and means to ensure proper pet waste
disposal.
E. Rationale for New Goals
MSD has a storm water rate proposal that was supported by the Rate Commission to
establish a storm water fee to fund basic and enhanced storm water services.
Enhanced services are those that go beyond MSD’s basic services in maintaining the
public storm sewer system. If implemented as planned, up to five watershed advisory
committees will be formed to provide public input on the enhanced services that will be
provided by MSD. To support watershed management planning concepts, MSD will
present information to these committees to address water quality related issues.
Based on MSD’s experience in working with various groups on community and stream
clean-up events, public participation activities will be enhanced through an intentional,
coordinated clean-up effort involving all co-permittees.
Based on recommendations from the public, a rain garden, or rain barrel or similar
program will be pursued to involve the public in reducing storm water runoff.
Knowedgeable partners, good guidance and local expertise will be required.
Partnerships will be pursued to make this program successful.
Specific goals for each year of the permit are presented as follows:
Annually
MSD will report on the number of volunteer presentations supported.
MSD will report on the number of storm drain marking projects supported.
MSD will report on the number of volunteer neighborhood and stream clean-ups
supported.
St. Louis County will report on the amount of household hazardous waste collected.
Year 1
No new events planned.
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Public Involvement and Participation
Year 2
MSD will organize with partner organizations an annual Plan Area stream clean-up
event. Each co-permittee will participate with the planned event, or participate in their
own clean-up activity in the community. With success and commitment from partners,
the event will become an annual event.
Year 3
If MSD’s storm water rate proposal is adopted by the Board and the watershed advisory
committees formed as proposed, MSD will present water quality related issues and
activities to the watershed advisory committees for their consideration.
Year 4
MSD will develop a plan for implementation of a storm water management public
involvement program to reduce the volume and/or rate of discharge of storm water
generated from households, for example, a rain garden or rain barrel program.
Year 5
The storm water management public involvement program promotional and/or
educational information will be developed and distributed to the public.
MSD, supported by citizen volunteers, will publish a report of their activities, including
outcomes and recommendations for future volunteer activities.
5-4
Illicit Discharge Detection and Elimination
6-1
CHAPTER 6
Illicit Discharge Detection and Elimination (MCM 3)
A. MS4 Permit Requirements
Section 4.2.3.1.1 of the general MS4 permit requires the permittee to develop,
implement and enforce a program to detect and eliminate illicit discharges (as defined in
10 CSR 20-6.200) into the permittee’s small MS4.
10 CSR 20-6.200(1)(C)7 defines an illicit discharge as “any discharge to a
municipal separate storm sewer that is not composed entirely of storm
water, except discharges pursuant to a state operating permit, other than
storm water discharge permits and discharges from fire fighting activities.”
The program must include development and implementation of, at a minimum:
A storm sewer system map showing the locations of all outlets and
the names and location of all waters of the State that receive
discharges from those outlets;
An ordinance or other regulatory mechanism to effectively prohibit
non-storm water discharges into the permittee’s storm sewer
system, with appropriate enforcement procedures and actions;
A plan to detect and address non-storm water discharges, including
illegal dumping, to the permittee’s system;
Methods to inform public employees, businesses and the general
public of hazards associated with illegal discharges and improper
disposal of waste;
Plans to address the thirteen categories of non-storm water
discharges or flows, identified in Section 4.2.3.1.6 of the permit, only
if the permittee identifies any of them as significant contributors of
pollutants to the permittee’s small MS4; and
A list, subject to the conditions in Section 4.2.3.1.7 of the permit, of
other similar occasional incidental non-storm water discharges that
the permittee has determined will not be addressed as illicit
discharges.
The Planning Committee has not identified any listed category of non-storm water
discharge in Section 4.2.3.1.6 of the permit which significantly contributes pollutants to
Illicit Discharge Detection and Elimination
St. Louis County water bodies. Should any of the listed categories or other similar
occasional non-storm water discharges be found to contribute significant pollutants,
action will be initiated to effectively prohibit or control such discharges using existing
ordinance provisions and enforcement actions. The Planning Committee does not
believe there is a need to develop a list of allowable incidental non-storm water
discharges at this time. Under the existing program implementation, any incidental non-
storm water discharge that is identified as a potential source of significant pollutants,
appropriate local controls or conditions will be placed on such discharges.
B. Identification of Storm System Components
For many years MSD has utilized “facilities maps” which show the location, size, depth,
material of construction, and other useful information to identify sanitary sewers,
combined sewers, storm sewers and their appurtenances. These maps are used by
MSD staff engineers, maintenance personnel, private contractors, and others to “locate
and tie into” for collection and transport of wastewater and/or storm water from
commercial, industrial and residential properties.
Originally these facilities maps were sepia drawings that were copied and provided to
users in an indexed paper format. All maps have now been digitized and are accessible
in the office or field by computer. All MSD collection system maintenance personnel
have lap top computers that contain the most up-to-date versions of these maps.
MSD uses Intergraph Corporation’s Microstation GIS (graphical interface system)
Environment (MGE) as the mapping software of choice. There are several advantages
associated with this system.
MSD has facilitated the use of Windows NT 4.0 operating systems throughout its
business offices because of its known reliability and security. Intergraph’s MGE was the
first to move to the Windows NT environment in 1994. Intergraph also had their
developers work with other GIS vendors to encourage adoption of non-proprietary
standards for use and exchange of spatial data formats. MSD also had much useful
information spread through different areas that would be useful to share. Intergraph’s
MGE was a perfect choice because the tremendous amount of information could be
combined and shared utilizing a single GIS. As an initial starting point MSD’s
GIS/Mapping department has the sole responsibility to maintain and update the future
mapping layers onto a single server. Other departments needing this information can
use Intergraph’s GeoMedia software to capture, integrate, and maintain data from
supported data sources into specific departmental key projects.
The coordinate system used in the MGE environment at MSD incorporates the
following:
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Illicit Discharge Detection and Elimination
• Primary Coordinate System - State Plane 1927
• Zone - Missouri East
• Geodetic Datum - North American 1927
• Ellipsoid - Clarke 1866
Spatial analysis is performed using Intergraph’s Geomedia software and the same
coordinate system.
A schematic diagram depicting the process of locating and identifying sewers and
structures is presented in Figure 6.1 along with an abbreviated key of symbols and
numbering system utilized for structure identification.
Figure 6.1 Schematic of Sewer and Structure Location Procedure
There are an estimated 10,750 storm sewer outfall structures of various sizes and
configurations in St. Louis County. They may discharge drainage from a single lot or
from several city blocks. They often discharge storm water from one political jurisdiction
into another. Designation of these outfalls and other storm water conveyances for
permitting purposes would create a heavy administrative burden with little increase in
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Illicit Discharge Detection and Elimination
pollution control. When the number of outfall structures increases from construction in
undeveloped areas of St. Louis County, or when changes are made to existing systems,
MSD’s maps are updated. Because of MSD’s GIS mapping capabilities, updating the
separate storm sewer system is a continuing and routine task.
Since St. Louis County and its numerous incorporated municipalities were included in a
single storm water management plan, it was determined that only the storm water
outlets discharging storm water into the Mississippi, Missouri and Meramec Rivers need
to be identified for possible monitoring purposes.
Figure 6.2 shows the multitude of storm water outlets which discharge storm water from
the boundaries of the Plan Area. The insert enlargement on the figure below focuses
on one such outlet denoted by the “red star.” The map legend shows the outlet
identification number assigned to it. “SWO” is an acronym for “storm water outlet,” the
following single letter denotes the MSD service area, the next four characters indicate
on which facilities map the outlet appears, and the last three digits denote the outlet
number assigned to it. As noted in “red,” many of the drainage channels upstream of
the outlets have been enclosed.
Figure 6.2 Storm Water Outlets from Land Areas in St. Louis County
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Illicit Discharge Detection and Elimination
MSD has identified 202 storm water outlets exiting the Plan Area. These outlets have
been identified by designated numbers as explained above, the MSD service area, the
municipality where located and the major natural watercourse receiving the discharge.
The location of each specific point of discharge has been identified by state coordinates,
longitude and latitude and by Township, Range and Section. A complete listing of all
identified storm water outlets from the Plan Area is presented in Appendix A6–1. Since
the selected discharge points are natural drainage topography, updating of these
outlet’s locations and physical configurations will not be a major task.
For inclusion in this Plan, the MSD has also prepared maps to visually associate each
listed outlet with roadways and receiving streams. These maps are presented in
Appendix A6–2 with the first map serving as the Plan Area index for the more detailed
outlet maps.
C. Illicit Discharge Enforcement Mechanism
Since the late 1960s, MSD has utilized provisions in its sewer use ordinances to prohibit
illicit discharges into the separate storm sewer system. Currently, MSD Ordinance No.
8472 adopted August 14, 1991, is used as the legal enforcement tool to control such
discharges. Article IV of this Ordinance, “Control of Pollutant Discharges to Separate
Storm Sewers and Watercourses,” contains the following statement:
“Discharges to the District’s separate storm sewers enter waters of the
State directly or after conveyance through the District’s system and are
subject to NPDES permit regulations.”
It is further stated in the ordinance that:
“All users shall comply with the provisions of this article to ensure that
discharges from the District’s separate storm sewers do not violate
conditions of any of the District’s NPDES permits or of any NPDES permit
regulations, including storm water discharge regulations, or cause any
violations of State or Federal water quality standards.”
A specific provision (Article IV, Section One, Paragraph A) requires NPDES permits for
discharges to separate storm sewers:
“No person shall discharge any wastewater, treatment plant effluent,
cooling water, storm water or unpolluted water into any separate storm
sewer or watercourse unless such discharge is authorized by an NPDES
permit or is exempt from NPDES permit regulations and is not otherwise
prohibited by this Ordinance.”
Storm water associated with industrial activity is prohibited unless certain criteria are
met as described in Article IV, Section One, Paragraph B:
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Illicit Discharge Detection and Elimination
“No person shall discharge or cause to be discharged into any separate
storm sewer any storm water associated with industrial activity as defined
in 40 CFR 122.26(b) unless the discharge is in compliance with all
applicable provisions of the NPDES storm water regulations in 40 CFR
122.26 and any applicable State regulations and is in compliance with the
terms and conditions of any system-wide storm water discharge permit
issued to the District pursuant to those regulations.”
As noted in Chapter 7, the St. Louis County area has a trash and litter problem that will
require greater attention under Phase II Regulations. Provisions are contained in Article
IV, Section Two, Paragraph B that can be cited to prohibit trash discharges into area
watercourses:
“No person shall place or deposit into any outfall, drainage facility, storm
sewer or watercourse within the District any garbage, trash, yard waste,
soil, rock or similar material, or any other substance which obstructs flow
in the system or damages the system or interferes with the proper
operation of the system or which constitutes a nuisance or a hazard to the
public.”
Appropriate enforcement procedures and actions are contained in the ordinance to deal
with violators and to mitigate the effects of illegal discharges. Article IX - Enforcement,
lists various enforcement actions that can be initiated against a violator such as:
• Section One - Notification of Violation (verbal and written)
• Section Two - Administrative Orders (to include cease and desist order,
compliance order, show cause order and consent order)
• Section Three - Emergency Action (mitigative action taken by MSD)
• Section Four - Legal Action and Penalties (to include injunctive relief, consent
decree, and fines and imprisonment)
• Section Five - Liability Due to Violations (violator liable for expenses and
damages)
• Section Six - Recovery of Costs (MSD’s costs are reimbursable)
Depending on the severity of the violation, the response of the violator, and other
incident specific conditions, any and all of these enforcement tools are available to the
MSD.
Also available to the MSD is the authority to prohibit or regulate discharges by means
presented in Article VI, Section One under the heading “control alternatives.” In order to
ensure compliance, the MSD may take one or more of the following actions:
1. Prohibit the discharge;
2. Require pretreatment or treatment to a condition acceptable for discharge;
3. Require controls on the quantities and rates of discharge;
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Illicit Discharge Detection and Elimination
4. Require payment to cover added costs of handling and treating;
5. Require the development of compliance schedules;
6. Require the submission of reports necessary to assure compliance;
7. Require discharge permits;
8. Conduct inspections, surveillance and monitoring;
9. Require submission of management plans;
10. Require sampling and analysis of discharges;
11. Terminate service.
MSD has the necessary legal authority already in place to enforce provisions of the
Phase II Regulations at the local level in its role as coordinating authority. No additional
legal authority is considered necessary. Because of MSD’s existing legal authority and
experience in enforcing ordinance provisions, enforcement of Phase II regulatory
requirements was simply an expansion of normal business activities.
D. Illicit Discharge Detection/Elimination
Within St. Louis County, the MSD has 2,993 miles of separate storm sewers and over
10,750 identified outfalls. There are also an estimated 1,575 miles of surface streams,
which includes open natural and constructed drainage ditches and channels. MSD’s
program to detect and address illicit discharges to the storm water system, including
illegal dumping, involves a detection team of two people that will inspect the streams
during dry weather conditions. The primary focus is to look for potentially illicit
discharges, such as dry weather flows, and evidence of pollution in the stream from
illicit discharges. The capability for field screening exists through a pH, dissolved
oxygen and conductivity meter, plus sampling containers are carried for collecting
samples for laboratory analysis. Illicit discharges are also identified through various
engineering studies of the collection system, and illegal connections are reported to
MSD’s pollution control unit for investigation of responsible parties and to initiate
enforcement action.
As potentially illicit discharges are identified, a referral is made to investigate the finding.
The referral is made to MSD’s pretreatment unit to investigate regulated industrial
sources, the MSD pollution control unit to investigate all other discharges, and/or to
MDNR for non-compliant discharges from NPDES permitted facilities. As appropriate
after source confirmation, illegal discharges are refered to St. Louis County Department
of Health regarding solid waste issues and private laterals. The MSD investigation
procedure involves sewer map review, identification of possible sources of the pollutant
in the area, site inspections of probable facilities, covert sampling activities if needed,
and confirmation dye studies. Once the source or sources of the pollutants have been
identified, then the ordinance enforcement tools described earlier will be utilized to
mitigate the situation.
The team’s mission is to identify and document, not only illicit discharges to MSD storm
sewer systems, but also illegal dumping and infrastructure needs; such as, sanitary
sewer structures exposed by stream erosion. Such visual documentation and corrective
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Illicit Discharge Detection and Elimination
actions will help prevent spills of wastewater from sanitary sewers that are structurally
threatened. Problems are identified that also impact others, such as stream crossings,
erosion, or problems with debris buildup. The information obtained is shared with
municipalities and highway departments concerned with bridge protection; with sewer
district maintenance personnel concerned with collection system integrity and stream
blockages that could cause flooding; with engineering design staff concerned with
prioritizing capital projects involving sanitary and storm sewer systems; and others
assigned responsibility for erosion control.
MSD’s inspection schedule will ensure the entire Plan Area’s 1,575 miles of streams will
be inspected within a 5-year permit period. MSD’s stream mileage was calculated from
a hydrograph drawn from orthographic maps, and includes all open channels, streams,
creeks and observable ditches to any depth. The inspection mileage reported annually
is tabulated daily, based on inspections looking for outfalls and other concerns identified
above. Recording the findings from the inspections involves the use of a pocket PC and
GPS unit that records the findings with the GPS coordinates. In the office, the data is
downloaded into an Access database and is plotted on the MSD mapping software.
The MSD Engineering Department, Division of Environmental Compliance administers
the stream survey program.
E. Publicizing Hazards Associated With Illicit Discharges
Storm water runoff pollution is the major cause of water quality problems in most urban
watersheds. It must also be recognized that each individual is personally responsible
for the pollutants in the runoff from his or her occupied land area. The public education
measures of this Plan have addressed this issue from the public’s perspective by
informing individuals and households on the proper application of lawn fertilizers and
pesticides, pet waste control, car washing, waste management, and automotive fluid
changing plus others. The educational programs developed for illicit discharge hazards
will continue to be promoted with brochures and public service announcements under
MCM 1. MSD’s Phase II web page lists MSD’s 24 hour customer service line for
reporting illegal discharges, plus other agency contact information for spills, dumping,
and other environmental reporting.
Education can also raise awareness of water quality needs and pollution prevention
techniques for industry. Through the MSD Industrial Pretreatment Program and
associated facility inspections, industrial customers are given brochures explaining the
best practices for material handling and storage, fleet maintenance, and general waste
control practices. Where discharges are found to violate MSD’s ordinance or NPDES
permit regulations, the pretreatment enforcement response plan and procedures will be
followed. The MSD Division of Environmental Compliance will be responsible for such
information dissemination.
6-8
Illicit Discharge Detection and Elimination
F. Rationale for New Goals
With the implementation of the existing illicit discharge detection and elimination
program, ongoing program implementation goals will continue to be measured and
reported. For improving these programs, the new goals reflect the recognition of the
broad problem with solid waste, particularly trash and litter.
The Planning Committee determined that commercial and industrial sites represent
significant sources of trash and litter that enter the public storm drainage system.
Observations throughout the Plan Area indicated this is often the result of such sites
having inadequately sized waste storage units (dumpsters) and/or the insufficient
frequency of emptying those units. MSD’s fat, oil and grease program results in
thousands of food service and restaurant inspections annually to reduce grease
blockages in the sanitary sewer system. With minimal additional effort, this program
will be expanded to incorporate waste collection areas to address the trash problem.
Also, the planning committee recognizes the significance of septic tanks on water
quality, and the economic concerns dealing with related problems. A number of
resources and agencies address this topic, and a better informed, coordinated effort is
desired to address system maintenance and improper connections caused by outdated
codes. Therefore, a goal to address this topic has been included in this chapter.
The following is a listing of the illicit discharge detection and elimination components to
be implemented for each year of the permit period.
Annually
A goal will be established to reach at least 20% of MSD’s industrial customers each
year with an illicit storm water discharges brochure as measured by number of
brochures produced and distributed.
Illicit discharge detection surveys of all area streams will continue with 1400 miles of
open channel inspection reported during the permit term, averaging 280 miles of
streams surveyed per year over 5 years. MSD will report stream miles inspected, the
findings of the inspection, and the actions taken.
MSD will inspect outdoor waste handling areas at restaurants as part of the
interceptor/grease trap inspections, and report the number of inspections and violations.
Year 1
No new goals.
Year 2
No new goals.
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Illicit Discharge Detection and Elimination
Year 3
MSD and St. Louis County will form a work group to identify current activities, applicable
regulations and available resources concerning septic tanks, and develop a strategic
plan for addressing septic systems to minimize their impact on water quality,
coordinating between agencies.
Year 4
The strategic plan for addressing septic systems developed by the work group will be
distributed among involved agencies for implementation.
Year 5
No new goals.
6-10
Construction Site Storm Water Runoff Control
7-1
CHAPTER 7
Construction Site Storm Water Runoff Control (MCM 4)
A. MS4 Permit Requirements
Section 4.2.4.1 of the general MS4 permit requires the permittee to develop, implement
and enforce a program to reduce pollutants in storm water runoff from construction
activities that result in a land disturbance of greater than or equal to one acre.
Reduction of storm water discharges from construction activity disturbing less than one
acre shall be included in the program if that construction activity is part of a larger
common plan of development or sale that would disturb one acre or more. The program
must include development and implementation of, at a minimum:
An ordinance or other regulatory mechanism to require erosion and
sediment controls, as well as sanctions to ensure compliance, to the
extent allowable under State or local law;
Requirements for construction site operators to implement
appropriate erosion and sediment control best management
practices;
Requirements for construction site operators to control waste such
as discarded building materials, concrete truck washout, chemicals,
litter, and sanitary waste at the construction site that may cause
adverse impacts to water quality;
Procedures for site plan review which incorporate consideration of
potential water quality impacts;
Procedures for receipt and consideration of information submitted
by the public; and
Procedures for site inspection and enforcement of control measures.
B. Land Disturbance Requirements
Within the Plan Area, construction and land disturbance activities are performed by
private entities, as well as by MSD, St. Louis County, and many of the municipal co-
permittees. Land disturbance activities conducted by the co-permittees are handled in-
house or with the use of a contractor. These activities fall under the land disturbance
permitting requirements of the MDNR’s Water Protection Program for projects disturbing
one acre of more of land.
As a result of the first Phase II permit, each Plan Area co-permittee has amended its
existing construction and land disturbance program or developed a new program, which
Construction Site Storm Water Runoff Control
includes adoption of appropriate Phase II compliant policies, procedures, and
ordinances to reduce pollutants from construction activities that result in a land
disturbance of equal to or greater than 1 acre in size. Activities conducted by private
entities are subject to the land disturbance permitting requirements of the co-permittee,
depending upon the governmental jurisdiction within which the site is located. In
addition to any local approvals, every construction site operator must also obtain a
separate state permit for any land disturbance activities affecting an area of one acre or
more. Regardless of the status of local approvals, land disturbance activities on such
sites may not commence prior to the issuance of a state land disturbance permit.
C. Land Disturbance Activities
The co-permittees and their areas of responsibility include:
1. Metropolitan St. Louis Sewer District
MSD has primary responsibility and authority to review and approve plans and
specifications for sewerage and drainage works within the Plan Area. Any public or
private sewerage or drainage works proposed to be constructed, altered or
reconstructed by any person or corporation, public or private, within the District
boundaries, must be reviewed by MSD. This review incorporates the post-construction
storm water management controls required by MCM 5, as discussed in the next
chapter. MSD does not review and approve land disturbance projects, except when the
District performs or contracts for its own land disturbance activities.
2. St. Louis County
Two departments within St. Louis County government are involved in the authorization
and inspection of construction and land disturbance activities:
Department of Public Works (DPW)
As per Section 4.310 of the St Louis County Charter, effective November 6, 1979, the
DPW issues permits and performs inspections of all construction activities on private
property within the unincorporated areas of Saint Louis County. In addition, the DPW
issues permits and provides inspection services on all county government owned
projects and also provides inspection services for grading permits issued by the St.
Louis County Department of Highways and Traffic on private property. The DPW also
provides, by contract, permitting and inspection services to most of the municipal
governments in the county. As per Section 1101 of the St. Louis County Revised Code,
the DPW serves as the coordinator of major development projects, acting as the central
control on permit issuance. The DPW holds issuance of any permit until all other
government jurisdictions have signed off on the project: Zoning, Highways, Health and
MSD.
7-2
Construction Site Storm Water Runoff Control
Department of Highways and Traffic
As per Section 1105 of the St Louis County Revised Code, the H&T Department issues
permits and performs inspections of all projects in county right-of-ways. The H&T
Department also performs land disturbance storm water pollution prevention plan
reviews and issues permits for all projects within the flood plains of the unincorporated
area of the county. The H&T Department also issues permits for grading required on
subdivision developments. In addition, the H&T Department also performs or contracts
for its own land disturbance activities while performing maintenance, repair, or
construction of county roadways.
Two other county government departments own and operate facilities in the Plan Area
and may be involved in land disturbance activities.
Aviation Department
The Spirit of St. Louis Airport in Chesterfield is wholly owned by the St. Louis County
government. The Airport serves as the landlord for a major industrial park, out-leasing
buildings and land to business activities both associated with flight operations at the
airport and activities completely independent of flight operations.
Parks Department
This department owns and operates 78 county parks throughout St. Louis County both
in the unincorporated areas and in the municipal areas. The Parks Department may
perform land disturbance activities within these facilities either with in-house personnel
or by contract.
D. MDNR Land Disturbance Permit Requirements
The Missouri Department of Natural Resources has developed a number of general
land disturbance NPDES permits to cover varying situations throughout the state. Two
of these have particular applicability to the St. Louis County Plan Area.
General permit MO-R100000 covers land disturbance activities conducted
by a city, county or other governmental jurisdiction having a state
approved land disturbance program.
General permit MO-R109000 covers land disturbance activities conducted
by any entity, where discharges from the activity will discharge to water
bodies identified by the state as “Valuable Resource Waters.” The
previously listed general permit can also cover these activities if the city,
county or other governmental jurisdiction has provided for discharges to
such waters within their approved programs.
7-3
Construction Site Storm Water Runoff Control
Each of these general land disturbance permits apply specifically to land disturbance
conducted by or under contract by the co-permittees, and contain additional
requirements not specifically identified within the MS4 permit requirements. Since some
of the co-permittees subject to this Plan currently utilize these general permits and since
any co-permittees may utilize them, the additional requirements of these permits are
addressed in this Plan. The MDNR requirements contained in the Requirements and
Guidelines sections of these permits are:
Site operators must develop Storm Water Pollution Prevention Plans
(SWPPP) specific to each site and must amend the plans whenever
certain conditions occur. The required contents of a SWPPP and the
conditions which would trigger SWPPP amendments are identified in the
permit Requirements section.
Good housekeeping practices shall be maintained to keep solid waste
from entering waters of the state.
All fueling facilities on site must adhere to applicable federal and state
regulations concerning storage (underground and above ground) and
dispensers;
Substances regulated under the Resource Conservation and Recovery
Act (RCRA) that are transported, stored or used on site must be managed
as per the provisions of this Act;
Site operators must designate individuals with overall responsibility for
environmental matters;
Paint, solvents, petroleum products and petroleum waste products and the
containers for these materials, must be stored according to BMPs and be
inspected for leaks and spills weekly;
Quarterly reporting of the list of active land disturbance sites to MDNR;
Site operators must inspect outfalls and any structures or BMPs at the site
provided to prevent pollution of storm water or to remove pollutants from
storm water to ensure all BMPs are continually implemented and are
effective. Inspections must be scheduled at least weekly and no later than
48 hours after a rainfall causes runoff, and the observed conditions noted
in weekly reports. Deficiencies must be corrected within seven days of the
report;
Site operators must post a copy of a public notification sign, as required by
MDNR.
7-4
Construction Site Storm Water Runoff Control
E. Plan Area Land Disturbance Programs
As required by the Phase II permit, co-permittees have implemented programs that
require erosion and sediment controls for construction site operators. Activities
conducted by private entities are subject to these land disturbance permitting
requirements of the applicable co-permittee, depending upon the governmental
jurisdiction within which the site is located.
1. St. Louis County
St. Louis County adopted a Land Disturbance Code (LDC) in October of 2003 and
modified the Administrative provisions of that Code in September of 2005. This was
accomplished under County Ordinances 21,578 and 22,468. The technical provisions
of the County's LDC are virtually identical to the provisions contained in the Model
Ordinance in Appendix A12-1 of the 2002 Plan. St. Louis County enforces the LDC in
unincorporated St. Louis County and in many municipalities in the County that have
contracted for the enforcement of the LDC.
The LDC separates land disturbances into two basic categories: Major Land
Disturbances for land disturbance activities involving 1 acre or more of land or a site
involving less than 1 acre as part of a proposed developement that will utimately disturb
1 acre or more; and Ordinary Land Disturbances for land disturbance activity involving
less than 1 acre of land. The County currently issues approximately 30 major land
disturbance permits annually for residential developments and approximately 50 major
land disturbance permits for commercial developments.
The County's system of enforcement is outlined in the provisions of the Model
Ordinance contained in Appendix A12-1 of the 2002 Plan. For Major Land
Disturbances, this involves the following primary elements:
• Submission of land disturbance plans and SWPPP for review, approval and
permit issuance by the County.
• Assignment of a Special Inspector who is supplied by the permittee and
approved by St. Louis County. The Special Inspector is required to inspect the
site weekly, after heavy rains and inspect related to complaints. This Inspector is
required to report on each inspection to the Department of Public Works. If the
Special Inspector finds deficiencies, he is required to call for the deficiencies to
be corrected and to reinspect the site to confirm that the deficiencies have been
corrected. In the event they are not corrected, the Special Inspector is to request
the assistance of the County in causing the deficiencies to be corrected.
• The inspectors in the residential and commercial inspection sections of the
County's Code Enforcement Division also inspect Major Land Disturbance sites
for compliance with the LDC including BMP's. This is done in conjunction with
permits to construct facilities on these sites.
7-5
Construction Site Storm Water Runoff Control
• The residential & commercial inspection sections of the County's Code
Enforcement Division also have Senior Site Development Specialists who assist
inspectors in these sections in resolving major issues or concerns. These Senior
Site Development Specialists also review the reports of the Special Inspectors for
discrepancies and other problems and inspects Major Land Disturbance Sites, as
necessary to assure that descrepencies are corrected and problems resolved.
• The County also supplements, as necessary, Code Enforcement
Division inspections with inspections performed by inspectors from other
Departments.
The County Code Enforcement Division maintains records of weekly inspections by
Special Inspectors, complaints investigations by Special Inspectors and Code
Enforcement Division Inspectors, inspections after heavy rains, escrow release
inspections, and formal written violation notices as well as further deficiency correction
action.
The St. Louis County LDC contains monetary penalties for not obtaining required
permits and for other violations of the Code to include possible imprisonment. The
LDC contains provisions that allows the code official to stop the work, when deemed
necessary.
2. Municipalities
Each incorporated municipality has the authority and responsibility to perform
construction permitting and inspection services as a basic element of the police powers
afforded municipal governments in Missouri, and under the 2002 Plan, has implemented
a Phase II compliance land disturbance program to regulate construction within their
jurisdiction. Some municipalities provide full permitting and inspection services with
their own resources. These municipalities have adopted the model procedural guidance
manual and ordinance as is or with such enhancements as it deems appropriate to
meet its specific community needs. These municipalities have implemented the project
reviews, permitting, inspection, complaint response, and other activities needed to
implement the Phase II land disturbance program.
A second option many municipalities have taken is to adopt St. Louis County’s
ordinance and contract with St. Louis County for Code Enforcement. The County
contracts for permitting (including plan review and construction authorization
documents) and code enforcement, including periodic and critical event inspections.
The County contract requires the construction site operator to gain zoning approval from
the municipality for a project before a county permit is issued. In addition, the
municipality issues its final occupancy permits only after the Department of Public
Works has completed all construction inspections. In all cases the ordinance authority
and any penalties for non-compliance are the responsibility and authority of the
individual municipal governments.
7-6
Construction Site Storm Water Runoff Control
Finally, a third option implemented for those cities that are built out and have little
potential for land disturbance over one acre, was passing a resolution of no need,
prohibiting land disturbance over one acre, without a Phase II program in place.
3. Other Entities
In addition to the above local entities, the Missouri Department of Transportation also
engages in land disturbance activities within the Plan Area. As previously noted,
MoDOT’s activities, within the Plan Area, will be covered under a separate statewide
MS4 permit issued by MDNR to MoDOT, and the applicable storm water land
disturbance permit.
F. Rationale for New Goals
With the implementation of Phase II compliant land disturbance programs throughout
the Plan Area by co-permittees for all public and private construction projects, goals for
the next permit term will be focused on ensuring effective implementation of the
programs. Ongoing implementation measures will be reported, and shared among co-
permittees and the MDNR to ensure the regulated community’s compliance with the
program. Education of the construction community will be emphasized to ensure
requirements are understood, and to address common problem areas. The education
of program administrators will also be addressed to share tools and to ensure
consistent, effective implementation by the co-permittees.
Annually
Municipalities and St. Louis County will report permits issued by name and area
disturbed. This information was requested by MDNR for coordination to ensure land
disturbance program compliance.
Annually report the number of formal, written notices of violation and further
enforcement actions taken, and the companies they were taken against.
Year 1
St. Louis County and MSD with partners will develop a training program for developers
and construction company employees on sediment and erosion control BMPs. Training
will be tailored appropriately for experienced employees and those new to the land
disturbance regulations.
Year 2
St. Louis County and MSD with partners will provide training for developers and
construction company employees on sediment and erosion control BMPs. The
effectiveness of this land disturbance training will be evaluated.
7-7
Construction Site Storm Water Runoff Control
Year 3
St. Louis County and MSD will identify the top list of ordinance or BMP categories in
frequent noncompliance, and prepare and deliver a presentation or other educational
materials to present to construction companies and developers.
Year 4
St. Louis County and MSD will identify the tools and resources for municipalities to
improve implementation of the Phase II land disturbance program
Year 5
St. Louis County and MSD will hold a training workshop for municipal staff to cover
storm water pollution prevention plans, compliance inspections and program
enhancements identified in year 4. The municipal implementation of the suggested
tools and resources presented will be tracked.
7-8
Post-Construction Storm Water Management in New Development and Redevelopment
8-1
CHAPTER 8
Post-Construction Storm Water Management in New Development
and Redevelopment (MCM 5)
A. MS4 Permit Requirements
Section 4.2.5.1 of the general MS4 permit requires the permittee to develop, implement
and enforce a program to address storm water runoff from new development and
redevelopment projects that disturb greater than or equal to one acre, including projects
less than one acre that are part of a larger common plan of development or sale, that
discharge into the permittee’s small MS4. The program must ensure that controls are in
place that will prevent or minimize water quality impacts. Subsequent permit
subsections require that this program include the following:
Development and implementation of strategies which include a
combination of structural and/or non-structural BMPs appropriate for
the permittee’s community;
Use of an ordinance or other regulatory mechanism to address post-
construction runoff from new development and redevelopment
projects to the extent allowable under State or local law; and
Means to ensure adequate long-term operation and maintenance of
BMPs.
Policies and ordinances that provide requirements and standards to
direct growth to identified areas, protect sensitive areas such as
wetlands and riparian areas, maintain and/or increase open space
(including a dedicated funding source for open space acquisition),
provide buffers along sensitive water bodies, minimize impervious
surfaces, and minimize disturbance of soils and vegetation;
Policies or ordinances that encourage infill development in higher
density urban areas and areas with existing storm sewer
infrastructure;
Education programs for developers and the public about project
designs that minimize water quality impacts; and
Other measures such as minimization of the percentage of
impervious area after development, use of measures to minimize
directly connected impervious areas and source control measures
often thought of as good housekeeping, preventive maintenance and
spill prevention.
Post-Construction Storm Water Management in New Development and Redevelopment
B. Program Intent
In the previous chapter, procedures to control the quality of storm water runoff during
land disturbance activities throughout the Plan Area were discussed. In this chapter,
the post-construction storm water management program, after land disturbances and
development or redevelopment of the property is complete, is discussed and the
individual BMPs, measurable goals, and responsible entities are identified.
Before actual construction begins, a great deal of planning is necessary to ensure the
final project design complies with regulatory requirements and incorporates proven
BMPs for water quality protection to the maximum extent practicable. Many of the
natural watercourses within the Plan Area are affected by the intense urbanization
characterized by imperviousness exceeding 25%. Most streams within the Plan Area
are used as conduits for conveying storm water flows from these impervious areas, and
as a result, their ability to support a diversity of aquatic life has been compromised, and
they have experienced and continue to experience severe widening, down cutting and
stream bank erosion. The storm water management plan should give adequate
attention to means to prevent increases in imperviousness, attempt to reduce the
imperviousness already present when practicable, and address stream stability and
degradation.
Defining and describing specific priority areas within the Plan Area for more intense
post-construction BMP implementation was not considered appropriate since the
impacts of intensive urbanization are felt throughout the Plan Area. There are,
however, locations within the Plan Area, which could be considered for infill
development because of existing utility service and adequate sanitary and storm sewer
infrastructure. These “vacant property” sites could be redeveloped to protect what few
“green fields” remain within the Plan Area. Urban redevelopment and infill projects are
a means of helping rejuvenate aging cities and provide opportunities for more
environmentally friendly growth. The primary intent of Minimum Control Measure No. 5,
is to:
• channel development towards areas which can support that growth with
existing infrastructure,
• maintain the integrity of open spaces existing within the Plan Area, and
• incorporate appropriate watershed protection criteria in construction project
design.
C. Best Management Practice Implementation
The BMPs for post-construction storm water management in new development and
redevelopment are categorized under the permit as structural and non-structural.
Implementation of these BMPs in the Plan Area involves two different aspects due to
the political jurisdictions in the Plan Area and the differing responsibilities of these
authorities. One aspect is implemented by MSD through enforcement of design
requirements for storm water management facilities, and the other is through land use
8-2
Post-Construction Storm Water Management in New Development and Redevelopment
controlled through the planning and zoning authorities of the city and county
governments.
1. Metropolitan St. Louis Sewer District (MSD)
In the Plan Area all storm water facilities and controls must be reviewed and approved
by the MSD. Currently, the MSD requires all such facilities to be provided and designed
in accordance with provisions contained in the “Rules and Regulations and Engineering
Design Requirements for Sanitary Sewer and Stormwater Drainage Facilities”, dated
February 2006, as amended. To comply with the mandatory requirement under MCM 5
to “develop and implement strategies which include a combination of structural and/or
non-structural BMPs appropriate for the locale,” MSD has revised these Rules and
Regulations to include requirements for BMPs for storm water control and watershed
protection to be incorporated into the project design. These rules and regulations are
implemented under the authority of MSD Ordinance 9030, and the Rules and
Regulations implementing the Phase II BMPs were adopted by the MSD Board of
Trustees in Resolution 2630.
The Rules and Regulations include storm water design criteria for: flood protection
using the 2 year and 100 year 24-hour events, water quality treatment using runoff from
90% of daily events, and channel protection storage using the one-year 24-hour event.
To meet the water quality criteria, storm water management facilities must treat the
water quality volume using an acceptable Urban BMP, as defined in the the Rules and
Regulations, which adopts the Maryland Stormwater Design Manual. The five general
categories of Urban BMPs include:
• Storm water ponds,
• Storm water wetlands,
• Infiltration practices,
• Filtering practices, and
• Open channel practices
Non-structural BMPs are recognized as beneficial storm water BMPs, particularly as a
critical feature of better site designs. Non-structural BMPs are beneficial by reducing
the generation of storm water from the site, and preserving environmentally sensitive
areas. To promote the use of non-structural BMPs, a series of credits are provided for
developments that use these BMPs in their site planning:
• Natural area conservation,
• Disconnection of rooftop runoff,
• Disconnection of non-rooftop runoff,
• Reserved buffers,
• Open channel use,
• Environmentally sensitive development, and
• Impervious cover reduction
8-3
Post-Construction Storm Water Management in New Development and Redevelopment
The Rules and Regulations require site designers to submit a Stormwater Management
Facilities Report. The Report will contain the operation and maintenance requirements
specific to the design, and is approved by MSD prior to installation. Upon installation,
MSD inspects facilities to ensure they were constructed according to the approved
design. All BMPs will be maintained by the property owner(s), and MSD will enforce the
maintenance through a Maintenance Agreement recorded with the property records. An
enforcement program will be used to ensure property owners maintain the BMPs.
To promote a reduction in imperviousness both in new development and redevelopment
projects, MSD has proposed to the Board of Trustees and the Rate Commission the
adoption of a storm water user charge system based on a property’s degree of
imperviousness to cover basic storm water services to cover the operation and repair of
the existing public storm water system. A storm water charge is proposed for enhanced
services to cover additional services, as approved by MSD’s Board.
2. Planning and Zoning Authorities
Watershed protection is directly related to urban development and growth
characteristics within the watershed. There are many planning and zoning strategies
that can be developed by municipal governments to encourage growth in areas that can
best support the type of growth desired while maintaining overall integrity of the
watershed. Working in cooperation with St. Louis County government and the
municipal governments in the County, the MSD has developed and distributed
educational materials on planned growth and watershed protection to the co-permittees
in the Plan Area. An educational booklet, “Planning and Zoning Strategies for Water
Quality Protection”, March 2006 was disseminated to all co-permittees, engineers and
developers to promote water quality protection in planning and zoning regulations.
The Planning and Zoning booklet identifies eight land use strategies that can be used to
protect water quality. Plan effectiveness will be measured by tracking the number of
municipal ordinances adopted during each year of the permit that have incorporated
planned growth BMPs into their planning and zoning regulations. In May 2007, all co-
permittees were instructed to pass one of the appropriate strategies or use another
option to address the post-construction storm water management requirements by the
end of the first permit term. The eight strategies in the Planning and Zoning booklet
include:
• Stream buffer,
• Planned unit development (PUD) performance criteria,
• Overlay zoning,
• Conservation subdivision ordinance,
• Infill redevelopment,
• Tree preservation,
• Flood plain protection, and
• Conservation easement
8-4
Post-Construction Storm Water Management in New Development and Redevelopment
The intent of post-construction ordinances is to require better site designs up front in the
planning and zoning review and approval process to accommodate a menu of non-
structural best management practices for post-construction runoff. From the eight
strategies identified in the Planning and Zoning Strategies booklet, three types of post-
construction ordinances clearly meet this goal: planned urban development (PUD)
ordinances with water quality based criteria (with standards for stream buffers, open
space, and impervious surfaces), overlay zoning requiring better site designs to protect
environmentally sensitive areas (like streams, wetlands and flood plains), and stream
setbacks with vegetated buffers. It is believed that three additional strategies may also
satisfy the permit requirement: the conservation subdivision ordinance, the infill
redevelopment strategy (when the focus and effect protects green space), and the
conservation easement strategy (when a dedicated funding source exists and acquired
property protects streams, wetlands and flood plain areas). MDNR identified one of the
eight strategies that will not satisfy the permit requirement alone, the tree preservation
strategy. MSD also believes that the flood plain protection strategy will not satisfy this
permit requirement, unless the ordinance greatly exceeds the minimum standards of the
National Flood Insurance Program.
3. Missouri Department of Transportation
The Missouri Department of Transportation (MDOT) is subject to a MS4 General
Operating Permit issued by the Missouri Department of Natural Resources, Water
Pollution Control Program. The MDOT’s permit contains the same Phase II storm water
requirements for post-construction storm water management as the St. Louis MS4.
Therefore, MDOT projects will not be subject to the St. Louis County Phase II Storm
Water Management Plan.
D. Flood Control
The MSD has been involved with flood control since its inception. The MSD has
constructed numerous channel improvement projects to alleviate flooding and erosion,
and also constructed many storm sewer projects to alleviate localized street and
backyard flooding. These projects are located within the original boundaries of the
District where capital improvement projects are supported by ad valorem taxes.
Outside the original boundaries, St. Louis County and the municipalities have also
constructed channel improvement projects and storm sewer projects. Inadequate
culverts and bridges have been replaced by the agencies that are responsible for the
road and highway maintenance.
In 2000 the MSD completed a Stormwater System Master Improvement Plan (SSMIP)
to provide a comprehensive and coordinated plan for resolving storm water problems
throughout the District. Many flood control projects were identified in the SSMIP, of
which a number contained non-structural solutions. Because structural solutions to
flooding and erosion problems are often very costly, acquisition of the affected
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Post-Construction Storm Water Management in New Development and Redevelopment
properties is sometimes a more cost-efficient approach. The MSD recently purchased
several flood prone houses in the River Des Peres watershed. The SSMIP also
identified numerous locations where flood proofing could be a viable alternative to
traditional structural flood control methods that may not be suitable or cost effective.
The MSD has developed a flood proofing program, and flood proofing is one of the
options considered when evaluating storm water solutions on projects.
The Plan Area has several flood control levee districts along the Missouri River. These
include the Monarch – Chesterfield Levee District, the Howard Bend Levee District,
Riverport, and the Earth City Levee District.
The local municipalities and St. Louis County have primarily managed floodplain
requirements because it is an issue closely related to zoning and land use restrictions.
A list of flood prone communities is provided in Table 8.1 from the St. Louis County
Flood Insurance Study. These local governments have ordinances that fulfill the
minimum requirements of the National Flood Insurance Program administered by
FEMA, and some include slightly more restrictive requirements. Most of the
municipalities listed are co-permittees and are involved in this Plan. Only ten
municipalities on this list are exempted from Phase II compliance due to combined
sewers or population served.
Floodplain studies are required for new development to insure the new structures are
protected from the 100-year flood. MSD requires a floodplain study for any
development that is to be in the 100-year floodplain. In addition, a 100-year hydraulic
study is required if any watercourse cannot be contained in a 60-inch pipe for the 15-
year event. MSD Rules and Regulations require the lowest floor of any structure to be
at least one foot above the 100-year flood elevation, and the low sill must be two feet
above the 100-year flood elevation. Floodplain filling is subject to state or local
government restrictions, and thus MSD has no requirements for compensatory storage
when development takes place in the floodway fringe. St. Louis County requires
compensatory storage except in the floodplains of the Mississippi, Missouri and
Meramec Rivers.
Since the early 1970’s, storm water detention has been required for new development
to control flooding of downstream properties. The MSD currently requires storm water
detention for new developments that have a differential runoff of two cubic feet per
second or greater between pre- and post-development flow. Detention is also required
when special conditions or problems exist downstream of a new development. The
post-developed peak flows are limited so that downstream peak flows and stages are
not increased above pre-development conditions for the 2-year and 100-year, 24-hour
events.
8-6
Post-Construction Storm Water Management in New Development and Redevelopment
Table 8.1 Flood-Prone Communities
FLOOD-PRONE COMMUNITIES
Ballwin Florissant Olivette
Bella Villa* Frontenac Overland
Bellefontaine Neighbors Grantwood Village* Pagedale
Bel-Ridge Green Park Richmond Heights
Berkeley Hanley Hills Riverview
Black Jack, City of Hazelwood Rock Hill
Breckenridge Hills Huntleigh* Shrewsbury
Brentwood Jennings St. Ann
Bridgeton Kinloch* St. John
Charlack Kirkwood Sunset Hills
Chesterfield Ladue Town and Country
Clarkson Valley Lakeshire University City*
Clayton MacKenzie* Valley Park
Cool Valley Manchester Velda Village Hills*
Crestwood Maplewood* Webster Groves
Creve Coeur Maryland Heights Wellston*
Des Peres Moline Acres Westwood*
Ellisville Northwoods Wildwood
Fenton Norwood Court Winchester
Ferguson Oakland St Louis County,
Unincorporated Area
* Exempt from Phase II Regulations
E. Rationale for New Goals
Previous sections of this chapter have dealt with activities carried out by co-permittees
in the implementation of a post-construction storm water program. The goals for this
Plan involve ongoing reporting of program measures and significant educational efforts
to enhance compliance with these new programs.
With the new Rules and Regulations implemented by MSD, a strong partnership and
working relationship with each of the municipalities and St. Louis County is desirable.
The cities can help ensure that all applicable development plans are submitted to MSD
for approval, and that site designs will successfully incorporate both structural and non-
structural best management practices. Cities must not only be aware of the BMPs
required by MSD, but when knowledgeable, can assist site developers early in planning
8-7
Post-Construction Storm Water Management in New Development and Redevelopment
and zoning review by ensuring site designs allow the appropriate space for BMPs to be
used. Also, cities can play an important role in ensuring the proper maintenance of
BMPs through ordinances regulating management of properties, to ensure nuisances
are not created by property owners not maintaining the BMPs. Implementation of non-
structural BMPs can further be encouraged through various planning and zoning
strategies that require preservation of water resources and open space. MSD offers a
conceptual review service that can address storm water management under MSD’s
rules early in the design phase of a project, and ensure acceptability of the design under
MSD’s Rules and Regulations.
In addition to the co-permittees working effectively toward the same goals, public
education will be another key element in implementing and maintaining effective post-
construction BMPs. In the development community, educational efforts will encourage
the use of a combination of the post-construction BMPs, particularly the non-structural
BMPs. To ensure the proper operation and maintenance of BMPs, education of the
public will be key, focusing on the responsibilities of homeowners and subdivision
trustees and the required maintenance of BMPs. The public understanding of the
important role BMPs perform to protect water quality, as well as the expectations of how
they perform in managing storm water, will be key to ensuring the public acceptance of
BMPs and ensuring they are well maintained and continue to function properly.
In summary, the activities to be undertaken to comply with MCM 5 requirements are
listed by year of implementation as follows:
Annually
MSD will report the number of BMPs approved/installed, and the number of BMPs
inspected to ensure proper operation and maintenance.
MSD will report the number of developments utilizing the conceptual review service.
Year 1
MSD and partners will develop educational material for municipal public works,
developers and engineers on MSD’s urban BMPs, and to promote the use of non-
structural credits and the benefits of site storm water management planning prior to land
disturbance.
MSD will provide storm water management BMP considerations and guidelines to
municipalities’ public works and planning and zoning reviewers to ensure the setbacks,
open space, and real estate needed for the installation of structural and non-structural
BMPs are allotted in the concept review of site plans.
Co-permittees will implement procedures to ensure all applicable private and public
projects involving storm water management are reviewed and approved by MSD.
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Post-Construction Storm Water Management in New Development and Redevelopment
Year 2
MSD and partners will begin distributing educational materials to municipalities,
developers and design engineers on MSD’s urban BMPs, and to promote the use of
non-structural credits and the benefits of storm water management planning prior to
land disturbance.
A work group will be formed of stakeholders to identify and evaluate legal impediments
to the design, installation, operation and/or maintenance of non-structural BMPs allowed
under MSD’s Stormwater Design Rules and Regulations. The evaluation may include
roadway design criteria, subdivision standards, zoning ordinances, property
maintenance codes or others, as applicable. Findings, recommendations and models
will be established.
Municipalities and St. Louis County will adopt and implement at least one additional
directed growth planning and zoning strategy to protect water quality, such as green
space and buffer criteria in overlay zoning and PUDs, or stream buffers from the P&Z
booklet or equivalent conservation method. Cities that have previously implemented
ordinances or procedures that require better site design, such as stream buffers or
minimum open space requirements or maximum impervious surface requirements
utilizing at least two strategies throughout their community will have satisfied this goal.
Year 3
The findings, recommendations and models of the legal impediments to the design,
installation, operation and/or maintenance of non-structural BMPs will be distributed
appropriately.
MSD and partners will develop an educational reference library (toolbox) for BMP
engineering design requirements.
Year 4
Municipalities will be asked by MSD to pass ordinances under their property
maintenance or other codes to require owners of structural and non-structural BMPs to
maintain them, as practical and allowed by the city’s legal authority.
Speaking engagements by MSD or partners at LEED green building venues or other
low impact development programs will be used to gain awareness of the BMP toolbox
and to promote better site designs for storm water management.
Develop educational materials for homeowners and subdivision trustees to explain the
purpose and function of structural and non-structural BMPs with the goal of gaining
acceptance of the BMPs in the community and to explain the property owners’
responsibility and the BMP maintenance requirements to ensure these BMPs function
properly.
8-9
Post-Construction Storm Water Management in New Development and Redevelopment
Year 5
Distribute educational materials to the public for subdivision trustees and homeowners,
distributing directly or via outlets such as title companies, etc., utilizing an O&M manual,
pamphlet or other appropriate method.
8-10
Pollution Prevention/Good Housekeeping for Municipal Operations
9-1
CHAPTER 9
Pollution Prevention/Good Housekeeping for Municipal Operations
(MCM 6)
A. MS4 Permit Requirements
Section 4.2.6.1 of the general MS4 permit requires the permittee to develop and
implement an operations and maintenance program that includes a training component
and has the ultimate goal of preventing or reducing pollutant runoff from municipal
operations. The program is required to specifically address the following areas:
Maintenance activities, maintenance schedules and long term
inspection procedures for controls to reduce floatables and other
pollutants to the permittee’s MS4;
Controls for reducing or eliminating the discharge of pollutants from
streets, roads, highways, municipal parking lots, maintenance and
storage yards, waste transfer stations, fleet or maintenance shops
with outdoor storage areas and salt/sand storage locations and snow
disposal areas the permittee operates;
Procedures for the proper disposal of waste removed from the
permittee’s MS4 and area of jurisdiction, including dredged
materials, accumulated sediments, floatables and other debris;
Procedures to ensure that new flood management projects are
assessed for incorporation of additional water quality protection
devices or practices; and
Identification of the person(s) responsible for overall management
and implementation of the permittee’s pollution prevention/good
housekeeping program.
Section 4.2.6.1.2 of the general MS4 permit requires the permittee, using training
materials that are available from EPA, State, or other organizations, to develop
employee training to prevent and reduce storm water pollution from activities such as
park and open space maintenance, fleet and building maintenance, new construction
and land disturbances and storm water system maintenance.
Section 4.2.6.2.1 of the general MS4 permit requires the permittee to specifically list all
of its municipal operations which are impacted by the above listed requirements.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-2
B. Storm Water Discharges Associated with Industrial Activity
Section (2)(B)3.F of the Missouri Storm Water Regulations (10 CSR 20-6.200) requires
that municipalities obtain separate state NPDES permits for storm water discharges
from certain “industrial” facilities that are municipally owned or operated if the storm
water discharges from those facilities are not already covered under other NPDES
permits. Section (1)(B)16 of the regulations provides for a certification of “no exposure”
in lieu of a permit if the “industrial” activities are protected from rain, snow, snowmelt
and/or runoff and the operator meets certain other requirements.
Section 4.2.6.2.1 of the MS4 permit requires the permittee to include a list of such
“industrial” facilities, along with the NPDES storm water permit number for each facility
or a copy of the current NPDES storm water permit application. The regulations contain
an extensive listing of “industrial” facilities subject to this requirement. From that
extensive listing, only the following few are typically under municipal ownership and/or
operation:
Transportation, including Airports Solid Waste Transfer Facilities
Landfills Wastewater Treatment Facilities
Hazardous Waste Treatment/Storage/Disposal Recycling Facilities
Vehicle Maintenance Facilities Yard Waste Compost/Mulch Facilities
Vehicle Washing Facilities Warehousing and Storage Facilities
A separate municipal storm water permit is only required if storm water from any of
these “industrial” facilities discharges directly to waters of the state and the storm water
discharge is not already covered under another NPDES permit. Each co-permittee will
supply the required information for any “industrial” facilities they own or operate as part
of their individual MS4 permit applications.
C. Storm Water Conveyance Construction and O&M
The MSD charter authorizes MSD to construct or reconstruct (by contracts or otherwise)
any improvements, extensions or additions to provide adequate storm water drainage.
Capital improvements are the structural solutions to alleviate specific drainage problems
or to prevent them from occurring in the first place. Typical examples include replacing
an undersized culvert to pass greater flows or repairing a channel reach that is suffering
from extreme erosion. The MSD presently undertakes a very limited amount of storm
water capital improvement projects that fall into three categories:
• Operation, Maintenance and Construction Improvement (OMCI) Fund
Projects
• Replacement/Renewal Projects
• Emergency Projects
Certain watersheds have a specially assessed ad valorem tax used for capital projects
that benefit the particular area. These capital improvements are only done in
watersheds that requested an OMCI tax. A storm water rate proposal has been
developed by MSD that would establish a storm water rate which would cover the
maintenance and capital improvement needs of the entire Plan Area. These projects
are generally designed and managed by the MSD Engineering Department with private
contractors performing the construction.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-3
1. Operation, Maintenance and Construction Improvement (OMCI) Fund Projects
2. Replacement/Renewal Projects
Over time, drainage infrastructure may become degraded to the point of needing
replacement or substantial repair. Typical Replacement/Renewal activities include:
routine inlet repair/reconstruction, sewer replacement/rehabilitation, culvert
improvements, and improved stream bank repairs. These projects are currently only
done within the original boundaries of the District, and they are completed by the MSD
Operations Department or private contractors when deemed more efficient. Various
municipalities also have capital improvement programs that include storm water
projects. Some have a sales tax that is dedicated for storm water improvements.
Under MSD’s rate proposal, these projects would be funded as basic services by an
impervious charge.
3. Emergency Projects
The MSD charter explicitly gives MSD maintenance authority over all drainage facilities.
Operations and Maintenance (O&M) includes those activities required to run the District
storm water facilities on a daily basis and to keep the drainage system functioning as
designed. Storm water O&M includes the following services: operation of flood gate
and floodwall pump stations, emergency response to major rainfall or flooding events,
inlet cleaning, sewer cleaning, debris removal from culverts and open channels, erosion
repair, and complaint response.
4. Detention Basins
The responsibility for maintenance of detention basins is currently placed on the
property owner or homeowners association who have been required by covenant to
sign a maintenance agreement.
5. Roadway Culverts
Roadway culverts are currently maintained by the agency or individual responsible for
the road. The MSD will provide emergency services to remove significant blockages.
Storm sewers within the original boundaries of the District are routinely maintained by
the MSD. In the annexed area, the MSD will only provide emergency service, and the
routine maintenance is either done by the municipality or is not done at all. The MSD
does not maintain Missouri Department of Transportation storm sewers.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-4
6. Storm Sewers, Inlets, and Catch Basins
7. Improved Channels
The MSD will remove significant obstructions to flow and also undertake measures to
assure the structural integrity of the channel sides and bottom. This maintenance
includes any fences installed by the MSD that are integral to the improvements.
8. Natural Channels
Natural Channels are not routinely maintained by the MSD, but significant obstructions
to flow will be removed. Priority is given to blockages that cause major flooding. The
MSD will also undertake emergency control measures when there is a significant threat
from flooding or erosion, or to protect its sanitary facilities.
9. Trench Drains, Swales, Roadside Ditches, and Gutters
The MSD does not maintain any of these drainage components. Instead, these items
are the responsibility of the property owners or public entity with jurisdiction.
MoDOT has received a statewide MS4 permit, and will be solely responsible for meeting
all of the requirements of MCM 6 for its facilities and activities within the Plan Area.
These facilities include state and federal roads and highways, including storm water
conveyances located on the right of ways, parking and maintenance facilities for
vehicles and equipment, and storage facilities for salt and other materials.
D. Operation and Maintenance Program
The scope of municipal operations varies widely among the 61 entities involved in this
Plan. Municipal operations range from very small municipalities, having no municipal
facilities other than a few blocks of local streets, to the county government, having
responsibility for regional highways, parks, high rise municipal buildings, major
construction activities, fleet maintenance operations, airport and all the other various
and sundry operations of a major county government. Because of this broad variation
in activities, selection of appropriate BMPs to satisfy the permit requirements to the
maximum extent practicable will vary considerably among the co-permittees. Training
programs will be similarly varied. Each co-permittee has identified and listed their
operations that are impacted by the MS4 permit requirements referenced in Section A
above and have supplied the required information as part of their MS4 permit
application. Under the 2002 Plan, implementation of an Operation and Maintenance
The MSD organized a municipal work group and developed a model operation and
maintenance program to cover the operations identified in the permit application. Since
storm water runoff pays no attention to co-permittee jurisdictional boundaries it is
considered beneficial to have uniform minimum procedures for the Plan Area as a
whole. Development of this model program was completed in February 2005, and is
titled “Operation and Maintenance Program for the Prevention and Reduction of
Pollution in Storm Water Runoff from Municipal Operations within the City of
[Municipality Name], St. Louis County, Missouri”. The model program was submitted to
all co-permittees in a letter dated February 28, 2005. Since not all co-permittees have
identical facilities, services and operations, they were instructed to adopt only the
applicable chapters and elements of the 102 page model program, editing the model to
reflect the operations of the implementing organization. Co-permittees were instructed
to add measures, beyond those in the model, as it deems appropriate to meet its
specific community needs. As reported in St. Louis Metropolitan Small MS4 Annual
Reports, MSD and MDNR held several workshops to assist program managers in
implementing the operation and maintenance program, and training their employees.
As this Plan is being written prior to the end of the first permit term, it is expected that
each co-permittee will have implemented an adequate program by the end of the first
permit term.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-5
Program by each co-permittee was addressed in the first permit term. Table 9.1 lists a
summary of the commonly implemented BMPs applicable to municipal pollution
prevention.
In implementing the model program, co-permittees have identified the activities,
locations and responsible parties for management and implementation of the best
management practices for nine major activity areas. These major activity areas are
discussed below to cover all of the operations/activities engaged in by the 61 co-
permittees under this plan.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-6
Table 9.1 Summary of BMPs Currently Used for Pollution Prevention/Good Housekeeping
BEST MANAGEMENT PRACTICES
Pet Waste Controls
Pooper scooper ordinance
Ordinances addressing pet wastes on owner's property
Provide pet waste signs and stations in public parks, etc
Vehicle/Equipment Maintenance & Parking
Minimize solvent use
Use safer alternatives & recycled products
Clean up spills promptly & w/minimal use of water
Practice good housekeeping
Properly store & dispose of hazardous wastes
Recycle used oil, antifreeze, batteries, solvents, etc
Provide & maintain traps for drips from parked equip
Vehicle Washing
Use commercial facilities
On-site, capture, treat & dispose washwater to san sew
Illegal Dumping Control
Public Education Programs
Ordinance & enforcement against illegal dumping
Install/maintain structural controls for trash at outfalls
Recycling Facilities
Control & properly dispose runoff
Practice good housekeeping
Landscaping & Lawn Care
Employ planning & design using natural property conditions
Utilize soil analyses
Select plants appropriate to the region
Use non-turf plantings wherever possible
Irrigate efficiently
Use mulches & compost effectively
Minimize use of fertilizers, herbicides & pesticides
Pest Control
Employ integrated pest mgt program for muni facilities
Perform Street/Parking Lot Cleaning
Road & Bridge Maintenance
Calibrate deicer applicators to prevent over-application
Minimize maintenance activities during wet weather
Capture paint/rust particles during cleaning/painting
Perform Storm Drain System Cleaning
Properly Manage Muni Swim Pool Backwash/Drainage
Materials Management
Use Alternatives to Toxic Substance
Properly Store Hazardous Substances
Safely Store Road Salt & Other Deicing Materials
Have a Spill Prevention & Control Program
Maintain Regular Material Inventories
Identify hazardous & non-hazardous substances
Properly label all containers
Note materials requiring special handling/storage/disp
Employee Education/Training
Provide Edu/Train in Pollution Prevention, Environmental Technology, etc
This is the largest category since it incorporates general practices that can apply to
most municipal operations, from custodial activities in municipal offices to operation and
maintenance activities in shops, on streets and at satellite facilities. BMPs, under this
category include those dealing with materials management and storage, e.g. salt,
compost, etc., safe material substitutions, spill plans, establishment of standard O&M
procedures, scheduling, community regulation, record keeping and housekeeping
practices in general. Under community regulation, model ordinance language to
address various solid waste issues such as trash, litter, and pet waste was also
included in the model program. Some of the BMPs in this category will apply to every
co-permittee.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-7
1. General Housekeeping and Operation and Maintenance
2. Vehicle/Equipment Repair and Maintenance Operations
In addition to the applicable practices from general category #1, BMPs under this
category address such things as preventative maintenance and drainage from fleet
parking areas. Many of the small municipal co-permittees do not engage in these
operations and will not need to address them within their programs. The BMPs in this
category will apply to MSD, St. Louis County and those municipal co-permittees that
engage in such activities.
3. Vehicle/Equipment Washing
BMPs under this category address drainage from washing areas and use of commercial
facilities. As in category #2, many of the small municipal co-permittees do not engage
in these operations and will not need to address them within their programs. The BMPs
in this category will apply to MSD, St. Louis County and those municipal co-permittees
that have vehicles/equipment that is washed.
4. Facility Repair, Remodeling and Construction
Repair, remodeling, and construction activities at municipal facilities can generate
wastes similar to those identified in MCM 4 for construction and land disturbance
activities. BMPs under this category address erosion and sediment control,
minimization of impervious areas and the applicable general practices from
housekeeping and O&M practices. MSD, St. Louis County, and several of the larger
municipal co-permittees routinely engage in such activities. Even the smallest co-
permittee has the potential to engage in such activity. The BMPs in this category can
apply to every co-permittee.
Each of the co-permittees has some responsibility for roadway maintenance. Only St.
Louis County is involved with highway maintenance. The responsibilities of the other
co-permittees vary considerably, depending on their size and the extent of their
infrastructure. BMPs under this category address such things as pavement cleaning,
deicing material storage and use, erosion, and sediment control and capture of
pollutants during maintenance work. Some of the BMPs in this category will apply to
every co-permittee.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-8
5. Cleaning and Maintenance of Roadways, Highways, Bridges, and Parking
Facilities
6. Maintenance of Parks, Green Spaces, Trails, and Landscaping
Except for some of the smaller municipalities all of the co-permittees have
responsibilities under this category. These responsibilities vary greatly from maintaining
only a small green space around a village hall to maintenance of regional parks and
public recreation areas. BMPs under this category address such things as good
planning and design, integrated pest management, effective irrigation and smart usage
of fertilizers, herbicides and pesticides. The BMPs in this category will apply to MSD, St.
Louis County and those municipal co-permittees that have such land areas to maintain.
7. Cleaning and Maintenance of Drainage Channels, Storm Sewers, and Inlet
Structures.
The MSD has the major responsibility for this activity within the Plan Area. MSD
cleaning operations for enclosed conveyances typically involve flushing to a point of
collection and use of a Vactor truck to remove the materials for proper disposal. Other
co-permittees are responsible only for public storm water conveyances that have not
been dedicated to MSD. These include conveyances that do not meet MSD standards
for acceptance, conveyances that are contained entirely within a municipal complex or
facility area and crossroad culverts under municipal roadways. Such conveyances
remain the responsibility of the owning co-permittee. BMPs under this category address
such things as proper scheduling and employment of non-polluting cleaning methods.
The BMPs in this category will apply primarily to MSD but will also apply to a lesser
extent to many of the co-permittees.
8. Operation and Maintenance of Recycling Facilities
Only a small number of the co-permittees currently operate permanent recycling
facilities where citizens can drop off recyclable materials such as glass, plastic, paper
and similar items. A greater number of co-permittees operate facilities for recycling of
landscape wastes (leaves, clippings, tree trimmings, etc), from municipal operations or
collections. These facilities process such materials into mulch and/or compost which is
then used for municipal operations as well as made available to the community’s
citizens. BMPs under this category address such things as proper physical siting to
minimize storm water contact and routing of any runoff to proper disposal. The BMPs in
Responsibilities for this activity fall most heavily upon MSD, St. Louis County and those
municipal co-permittees bordering the major rivers or located in the lower reaches of
major watersheds. However, even the smaller municipal co-permittees can be involved
in managing localized flooding situations. BMPs under this category address
procedures to review new and existing flood management programs/facilities to
minimize impacts on water quality. The BMPs in this category will apply, to a greater or
lesser extent, to many of the co-permittees.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-9
this category will only apply to those co-permittees that operate recycling or composting
facilities.
9. Water Quality Impact Assessment of Flood Management Projects
E. Municipal Employee Training Program
The MS4 permit requires that the operation and maintenance program include a training
component. The education and training of municipal employees is necessary to
effectively implement this program. The training of municipal employees was employed
early in the Phase II process under the previous plan to accomplish immediate benefits
through municipal good housekeeping. Initially, nine workshops were held by MSD and
MDNR’s Environmental Assistance Office on the operation and maintenance program,
covering an overview of the program plus best management practices for general
housekeeping, vehicle and equipment maintenance, and facilities and parks
management. MSD continues to provide annual refresher training on best management
practices for the operation and maintenance program. MSD also makes other
information available to co-permittees, including a training DVD and a “Working
Together to Manage Stormwater Pollution” brochure available for employees and the
public summarizing the best management practices implemented under the program.
Many of the larger co-permittees have developed in-house training geared to their
specific needs and activities. Co-permittees are required to keep records and track their
training activities to document and ensure that all current employees received initial
training applicable to their job responsibilities and that new or re-assigned employees
receive training applicable to their new job responsibilities within a specified period of
time after employment. Provisions will be included for refresher training or training in
new procedures to ensure employee knowledge and skills are maintained and updated.
Materials produced for distribution to the public under MCM 1 are also provided to
municipal employees engaged in the types of activities to which those materials apply.
Municipal employees are encouraged to actively participate in the public education
efforts and public involvement activities discussed under MCM 1 and 2.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-10
F. Trash and Pet Waste Ordinances
Under the first plan, traditional municipal functions dealing with trash, litter and pet
waste were addressed through a specific initial effort, and then included as part of the
operation and maintenance program. In Year 1 of the 2002 Plan, co-permittees
evaluated their trash and pet waste control ordinances, and the need to modifly or pass
new ordinances. Model ordinance language was developed and submitted to co-
permittees for implementation to address the need. The model ordinance language has
also been incorporated into the good housekeeping provisions of the operation and
maintenance program. Those co-permittees that lacked adequate ordinances amended
existing ordinances or adopted new ones under the first permit term.
G. Rationale for New Goals
Previous sections of this chapter have dealt with activities carried out by co-permittee
staff in implementation of the operation and maintenance program under the first MS4
permit term. Under the second permit term, the co-permittees will maintain their
operation and maintenance programs and continue to provide refresher training to their
employees on best management practices. Additionally, several new goals will be
implemented to further the implementation of these programs and improve the best
management practices implemented. Successful implementation of various best
management practices will be identified and shared among all co-permittees to
encourage the implementation of as many of the best practices as possible in the Plan
Area. To accomplish this, case studies or educational information will be developed
and shared among co-permittees. Effective tools, such as a model checklist, will be
provided for municipal facility inspections. Due to the addition of chloride to the list of
priority pollutants under the Plan, an emphasis on related best management practices
has been given during training. However, the co-permittees will begin to report and
track the actual usage of de-icers annually.
Trash and litter in our communities and the storm water system is still a priority pollutant
under this plan. Under the 2002 Plan, the appropriate legal mechanisms for dealing
with trash were put in place through evaluation and passage of trash and pet waste
ordinances. Enforcement of ordinances is generally thought to be characterized in the
Plan Area as complaint driven. Depending on the various, numerous residential and
commercial sources of litter and solid waste, problems are thought to exist in identifying
the sources, obtaining legally defensible evidence, and enforcing the ordinances.
Therefore, goals will be included for the co-permittees to identify specific priority areas
in the communities, and develop and implement a plan to address the specificed areas.
A focused combination of efforts will be used to include: public education, public
involvement activities, and enforcing ordinances to address these problem areas.
The specific, reportable pollution prevention and good housekeeping activities to be
performed by co-permittees identified in this Plan are listed by permit year as follows:
Pollution Prevention/Good Housekeeping for Municipal Operations
9-11
Annually
Training in BMPs will continue as refresher seminars and workshops, and as BMP
introduction for new employees as co-permittees implement their ongoing employee
training programs. MSD will provide BMP refresher workshops for the co-permittees.
Co-permittees will report on the number of employees trained.
All co-permittees will inspect their facilities to ensure implementation of best
management practices and report the number of inspections annually. Inspection
findings will be incorporated into the co-permittee’s program review and employee
training program.
St. Louis County and municipalities will report salt usage per lane mile (as actual or
estimated), the application equipment and method used, and application rate(s)
selected and the selection methodology used in snow and ice removal from roadways.
Year 1
MSD will develop and distribute a municipal facility inspection template checklist based
on the model Operation and Maintenance Program.
A municipal work group will be organized to develop a guidance document that will
include a menu of approaches to address problem areas for illegal solid waste disposal
and the plan’s trash and bacteria water quality goals.
St. Louis County and MSD will develop a reporting form and guidance for tracking snow
and ice removal methodologies from roadways: such as product (i.e., salt) usage per
lane mile, the application equipment and method used, and the application rate(s)
selected and the selection methodology used.
Year 2
Municipalities and St. Louis County will identify specific solid waste (trash and pet
waste) problem areas in their community, make a priority list of sites to address, and
develop a plan of action in Year 2 to address these areas by March 2013.
All municipalities with parks will post pet waste signs in the parks.
Year 3
MSD and partners will identify and develop educational information or a case study, and
distribute to co-permittees to encourage implementation of a best management practice
regarding a calibrated spreader for road salt application, or similar practice.
Pollution Prevention/Good Housekeeping for Municipal Operations
9-12
Each co-permittee will continue to implement specific action plans with the goal to
address all solid waste (trash and pet waste) problem areas in the community by March
2013.
Year 4
MSD and partners will identify and develop educational information or a case study, and
distribute to co-permittees to encourage implementation of another best management
practice.
Each co-permittee will continue to implement specific action plans with the goal to
address all solid waste (trash and pet waste) problem areas in the community by March
2013.
MSD and St. Louis County will evaluate data on salt usage per lane mile, application
equipment and method, and application rate goals used in snow and ice removal from
roadways, and distribute a report of the evaluation that makes recommendations for
best practices.
Year 5
Each co-permittee will complete implementation of specific action plans to address all
solid waste (trash and pet waste) problem areas in the community by March 2013.
Record Keeping and Reporting
10-1
CHAPTER 10
Record Keeping and Reporting
A. MS4 Permit Requirements
Several sections of the general MS4 permit contain requirements pertaining to permittee
record keeping and reporting. These requirements, as listed below, apply to each of the
61 co-permittees in the St. Louis County Plan Area.
Section 4.1.2.3 requires the permittee to designate individuals responsible for
environmental matters. This section also requires the permittee to inspect any
structures that function to prevent pollution of storm water or to remove pollutants from
storm water and of the permittee’s area of jurisdiction in general to ensure that any
BMPs are continually implemented and effective.
Section 4.4 requires the permittee to do an annual review of the permittee’s storm water
management program (SWMP) in conjunction with preparation of the annual report
required under section 5.3. The permittee may update the program subject to the
following procedures as specified in the permit:
Changes adding (but not subtracting or replacing) components, controls or
requirements to the SWMP may be made at any time upon written notification to the
MDNR.
Changes replacing an ineffective or infeasible BMP specifically identified in the SWMP
with an alternate BMP may be requested at any time with the following information to be
supplied to the MDNR:
1. An analysis of why the BMP is ineffective or infeasible (including cost
prohibitive),
2. Expectations on the effectiveness of the replacement BMP, and
3. An analysis of why the replacement BMP is expected to achieve the goals of
the BMP to be replaced.
Section 5.1.1 requires the permittee to evaluate program compliance, the
appropriateness of identified BMPs, and progress toward achieving identified
measurable goals.
Section 5.2 requires the permittee to retain records of all activities requiring record
keeping by this Plan.
Section 5.3 requires the permittee to submit annual reports to the MDNR by April 10 of
each year of the permit term. The reports must include:
Record Keeping and Reporting
The status of the permittee’s compliance with permit conditions, an
assessment of the appropriateness of the identified BMPs, progress
towards achieving the statutory goal of reducing the discharge of
pollutants to the maximum extent practicable and the measurable goals
for each of the minimum control measures;
Results of information collected and analyzed, if any, during the reporting
period, including monitoring data used to assess the success of the
program at reducing the discharge of pollutants to the maximum extent
practicable;
A summary of the storm water activities the permittee plans to undertake
during the next reporting cycle (including an implementation schedule);
Proposed changes to the permittee’s SWMP, including changes to any
BMPs or any identified measurable goals that apply to the program
elements; and
Notice that the permittee is relying on another government entity to satisfy
some of the permittee’s permit obligations (if applicable).
B. Record Keeping
Each co-permittee will designate, on the co-permittee’s individual permit application, an
individual in overall charge of storm water management activities within the co-
permittee’s area of jurisdiction. That individual will be responsible for ensuring that:
• All elements of this Plan, pertaining to the identified co-permittee, are
effectively implemented;
• Required inspections are made;
• Required records are kept; and
• Information required for inclusion in reports to MDNR is provided to the
coordinating authority (MSD) upon request or as scheduled.
The permit specifies certain actions, such as inspections, which each co-permittee must
perform. In addition, this Plan identifies actions that the co-permittees are committed to
take in order to comply with the requirements of the Phase II Storm Water Regulations
and the terms and conditions of the MS4 permit. Measurable goals and time frames for
achieving those goals have been established. Accurate and timely record keeping by
each co-permittee is essential in order to document the timeliness and effectiveness of
committed actions, to demonstrate compliance with the permit requirements and to
provide the basis for the annual reports. Co-permittees must maintain documentation
regarding the implementation of programs and the maintenance of the programs under
the MS4 permit. Records are required to be maintained by the co-permittee for a
minimum of three years.
10-2
Record Keeping and Reporting
Following are examples of the types of actions for which records should be kept. This
listing is not all inclusive:
• Inspections as required by Section 4.1.2.3 of the permit (Record dates, areas
inspected, personnel involved, findings, follow-up actions, etc.). Each co-
permittee must conduct inspections within its area of jurisdiction for the
activities for which it is responsible under this Plan.
• Annual program evaluations as required by Section 4.4 of the permit (Record
evaluation method and results. If changes are proposed in the Plan, record
the reasoning behind the changes).
• Public information efforts under MCM 1 (Record dates, activity such as
brochure distribution, speaking event, etc.; type and number of people
reached, milestones in web site development, web site hits, results of public
knowledge surveys; etc.).
• Public involvement efforts under MCM 2 (Record milestones in public
involvement activity dates, nature of activities; applicable statistics such as
numbers of volunteers, numbers of people reached, quantities of waste
collected or removed, miles of stream or road cleaned, number of inlets
marked, pet pledge cards signed; etc.).
• Illicit discharge detection and elimination efforts under MCM 3 (Record
statistics such as miles of streams surveyed, number of illicit discharge
investigations initiated, number of stream problems identified; results of
investigations and problem identification; etc.)
• Construction site storm water control efforts under MCM 4 (Record
milestones in co-permittee program development, program
modifications/adoptions; statistics such as the number of permits issued;
etc.).
• Post-construction storm water management in new development and
redevelopment efforts under MCM 5 (Record milestones in review and
modification of existing regulations, and MSD approval of BMPs; ensuring the
operation and maintenance responsibilities for residential structural BMPs;
etc.).
• Pollution prevention/good housekeeping for municipal operations efforts
under MCM 6 (Record milestones in review and modification of existing
ordinances, development and adoption of a model O&M program,
development of a training program, dates, locations and subject matter of
training sessions; statistics such as numbers of training sessions held,
numbers of employees trained/refreshed; etc.).
C. Reporting
As the coordinating authority for the Plan Area, the Metropolitan St. Louis Sewer District
will compile the information provided by the individual co-permittees to satisfy the
10-3
Record Keeping and Reporting
permit’s annual review, program evaluation and annual report requirements. The
District’s Division of Environmental Compliance (DEC) will be responsible for
coordinating this activity and preparing and submitting the reports to MDNR.
The MSD DEC will develop appropriate standardized forms that co-permittees can use
to supply required information.
The MSD DEC will develop schedules for submittal of information required for reporting
purposes, including the annual reports.
10-4
BMP Goals, Measurements, and Responsibilities
11-1
CHAPTER 11
BMP Goals, Measurements, and Responsibilities
A. Purpose
The purpose of this chapter is to summarize in one convenient location within this Plan
the various BMPs and goals selected each year of the permit period to comply with
requirements of the six Minimum Control Measures. The entity within the Plan Area
responsible for implementation is also included. BMPs that are implemented as
ongoing programs list the permit year as “all” indicating the goal will be implemented in
each year of the permit. The information contained in this chapter summarizes what
has been presented in narrative format in each of the Chapters on MCMs for the
convenience of readers.
B. BMP Implementation Information
MCM 1: PUBLIC EDUCATION AND OUTREACH
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Brochures and other educational materials will be
distributed to improve water quality. Number distributed MSD
b. Presentations on water quality and nonpoint source
pollution education will be provided.
Number
presentations MSD All
c. Phase II web page visits. Number page visits MSD
1 a. A communication committee with partners will be
formed to develop/implement an outreach strategy.
Committee formed,
outreach products MSD
2 a. Develop a radio public service announcement and
distribute to radio stations.
Radio PSA
developed and
distributed
MSD
3
a. Distribute educational information on a relevant
topic District-wide using bill inserts, cable TV, or
other mass media.
Message delivered MSD
4
a. Distribute educational information on a relevant
topic District-wide using bill inserts, cable TV, or
other mass media.
Message delivered MSD
a. Distribute educational information on a relevant
topic District-wide using bill inserts, cable TV, or
other mass media.
Message delivered MSD
5
b. Conduct a survey to evaluate public awareness
and program effectiveness.
Number of
responses MSD
BMP Goals, Measurements, and Responsibilities
11-2
MCM 2: PUBLIC INVOLVEMENT AND PARTICIPATION
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Volunteer presentations Number supported MSD
b. Storm drain marker projects Number supported MSD
c. Neighborhood and stream clean-ups Number supported MSD
All
d. Household hazardous waste collection Waste volume St. Louis County
1 a. No new programs planned --- ---
2 a. MSD and co-permittees will organize an annual
Plan Area stream clean-up event.
Participation and
waste volume All co-permittees
3
a. If established by the Board, MSD will present water
quality related issues and activities to the storm
water watershed advisory committees.
Meetings and
presentations MSD
4
a. Develop a plan for implementation of a storm water
management public involvement program to
reduce the volume and/or rate of discharge of
storm water.
Program plan
developed MSD
a. Develop and distribute the storm water
management public involvement program
promotional and/or educational information to the
public.
Program
implemented MSD
5
b. MSD, supported by citizen volunteers, will publish
a report of their activities, including outcomes and
recommendations for future volunteer activities.
Report prepared
and published MSD
MCM 3: ILLICIT DISCHARGE DETECTION AND ELIMINATION
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Survey 1400 miles of area streams for illicit
discharge over permit term, averaging 280 miles
per year over 5 years.
Miles surveyed MSD
b. Distribute an illicit storm water discharges brochure
to 20% of MSD’s industrial customers each year.
Brochures
distributed MSD All
c. Inspect outdoor waste handling areas at
restaurants and other facilities as part of the
interceptor/grease trap inspections.
Inspections
performed MSD
1 a. No new programs planned. --- ---
2 a. No new programs planned. --- ---
BMP Goals, Measurements, and Responsibilities
11-3
Continue MCM 3
Permit
Year BMP Goal Selected Measurement
Method Responsibility
3
a. A work group will be formed to develop a strategic
plan for septic systems to minimize their impact on
water quality.
Work group formed MSD and St.
Louis County
4
a. The strategic plan for addressing septic systems
developed will be distributed among involved
agencies for implementation.
Strategic plan
distributed
MSD and St.
Louis County
5 a. No new programs planned --- ---
MCM 4 CONSTRUCTION SITE STORM WATER RUNOFF CONTROL
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Land disturbance permits issued will be reported
by name and area disturbed. Annual Report Municipalities &
St. Louis Co.
All b. Land disturbance program formal NOVs and
further enforcement actions will be reported, listing
the violating organizations.
Annual Report Municipalities &
St. Louis Co.
1
a. Develop a training program for developers and
construction company employees on sediment and
erosion control BMPs.
Program
developed
St. Louis County
and MSD
2
a. Provide training for developers and construction
company employees on sediment and erosion
control BMPs, and evaluate training effectiveness.
Training sessions St. Louis County
and MSD
3
a. Develop list of top ordinance or BMP categories in
frequent noncompliance, and deliver a
presentation or distribute educational materials to
construction companies and developers.
Presentations or
material distributed
MSD and St.
Louis County
4
a. Identify the tools and resources for municipalities to
improve implementation of their Phase II land
disturbance programs.
Resources
identified
MSD and St.
Louis County
5
a. Hold a training workshop for municipal staff to
cover storm water pollution prevention plans,
compliance inspections and program
enhancements identified in year 4, and track the
implementation of the tools presented.
Workshop
sessions
MSD and St.
Louis County
BMP Goals, Measurements, and Responsibilities
11-4
MCM 5: POST-CONSTRUCTION STORM WATER MANAGEMENT
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. BMPs approved/installed, and BMPs inspected to
ensure proper operation and maintenance.
Number of BMPs
installed and
inspected
MSD
All
b. Developments utilizing the MSD conceptual review
service will be reported. Number of reviews MSD
a. Develop educational material on BMPs and to
promote the use of non-structural credits and the
benefits of site storm water management planning
prior to land disturbance.
Material developed MSD
b. Provide storm water management BMP guidelines
to public works and planning and zoning reviewers
to assist in the concept review of site plans.
Material distributed MSD 1
c. Implement procedures to ensure all applicable
private and public projects involving storm water
management are reviewed and approved by MSD.
Procedures
inplemented
Municipalities
and St. Louis Co
a. Distribute educational materials to municipal public
works, developers and engineers on BMPs and to
promote the use of non-structural credits and the
benefits of site storm water management planning
prior to land disturbance.
Material distributed MSD
b. Evaluate legal impediments to the design,
installation, operation and/or maintenance of non-
structural BMPs allowed under MSD’s Stormwater
Design Rules and Regulations.
Evaluation
performed MSD 2
c. Adopt and implement one additional directed
growth planning and zoning strategy to protect
water quality, as necessary, to have two strategies
in place.
Ordinance or
strategy adopted
Municipalities
and St. Louis Co
a. Distribute a report on the legal impediments to the
design, installation, operation and/or maintenance
of non-structural BMPs.
Reports distributed MSD
3
b. Develop an educational reference library (toolbox)
for BMP engineering design requirements. Library developed MSD
BMP Goals, Measurements, and Responsibilities
11-5
Continue MCM 5
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Adopt ordinances under property maintenance or
other codes to require property owners to maintain
structural and non-structural BMPs, where
practical.
Ordinance adopted Municipalities
and St. Louis Co
b. Present at green building or other low impact
development venues to gain awareness of the
BMP library (toolbox) and to promote better site
designs for storm water management.
Presentation given MSD 4
c. Develop educational materials to explain the
purpose and function of structural and non-
structural BMPs in the community, and the
property owners’ responsibility for BMP
maintenance.
Educational
material developed MSD
5
a. Distribute educational materials explaining the
purpose and function of structural and non-
structural BMPs in the community to the public,
utilizing an O&M manual, pamphlet or other
appropriate method.
Material distributed MSD
MCM 6 POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Training on BMPs will continue as refresher
seminars and workshops. Workshops held MSD
b. Continue to implement O&M training program for
employees. Employees trained All co-permittees
c. Inspect facilities to ensure implementation of best
management practices.
Inspections
performed All co-permittees
All
d. Track and report salt usage per lane mile,
application equipment and method, and application
rate goal.
Quantity used Municipalities
and St. Louis Co
a. Develop and distribute a municipal facility
inspection template checklist based on the model
Operation and Maintenance Program.
Checklist
distributed MSD
b. Develop a guidance document with a menu of
approaches to address problem areas for illegal
solid waste disposal.
Guidance
developed MSD 1
c. Develop a reporting form and guidance for tracking
salt usage and application. Form developed St. Louis County
and MSD
BMP Goals, Measurements, and Responsibilities
11-6
Continue MCM 6
Permit
Year BMP Goal Selected Measurement
Method Responsibility
a. Develop a priority list of solid waste (trash and pet
waste) problem areas, a plan of action to address
these areas by March 2013.
Action plan
developed
Municipalities
and St. Louis Co
2
b. All co-permittees with parks will post pet waste
signs in the parks. Signs posted Municipalities
and St. Louis Co
a. Develop educational information or a case study,
and distribute to co-permittees to encourage
implementation of a best management practice.
Information
distributed MSD
3
b. Continue to implement action plans to address
solid waste (trash and pet waste) problem areas
by 2013.
Actions taken Municipalities
and St. Louis Co
a. Develop educational information or a second case
study, and distribute to co-permittees to encourage
implementation of a best management practice.
Information
distributed MSD
b. Continue to implement action plans to address
solid waste (trash and pet waste) problem areas
by 2013.
Actions taken Municipalities
and St. Louis Co 4
c. Distribute a report evaluating data on salt usage
per lane mile, application equipment and method,
and application rate goals used in snow and ice
removal, and recommend best practices.
Report distributed St. Louis County
and MSD
5
a. Complete implementation of action plans to
address solid waste (trash and pet waste) problem
areas.
Actions taken Municipalities
and St. Louis Co
C. Effectiveness of BMPs
It is considered by the Planning Committee that the BMP goals and measurements
identified in this chapter comply with the requirements of the Phase II Regulations and
that when implemented the pollution of storm water in the Plan Area will be prevented to
the maximum extent practicable.
Appendices
APPENDIX A3-1WATER QUALITY ANALYSIS10/10/01 3/20/02 10/2/02 3/19/03 10/9/03 3/4/04 10/12/04 3/22/0505:44 19:19 23:30 11:44 11:43 10:12 10:03 14:04ACUTE CHRONICDischarge (CFS) 42 56 113 117 353 104 64 249 42 353 137.25pH (units) 7.5 7.9 7.4 8 7.2 7.7 7.8 7.8 7.2 8 7.66Temperature (deg. C) 16.5 9 21.9 13.8 17.5 9.1 14.9 7.1 7.1 21.9 13.73Dissolved Oxygen (mg/l) 7.9 9.6 6.2 9.1 6.7 8.7 8 10 6.2 10 8.28 5Fecal Coliform (col/100ml) 42000 680 12700 917 36,000 8,000 2,200k 680 42000 16716.17 200Fecal Streptococci (col/100ml) 47000 860 24000 1440 55,000 860 55000 25660.00Ratio (Fec Coli/Fec Strep) 0.89 0.79 0.53 0.64 0.65 0.53 0.89 0.70Total Nitrogen as N (mg/l) 2.31 1.34 3.41 2.56 2.46 2.48 1.87 1.71 1.34 3.41 2.27Ammonia as N (mg/l) 0.08 0.08 0.13 0.2 0.05 0.11 0.05 0.24 0.05 0.24 0.12 8.92 1.08Total Phosphorus as P (mg/l) 0.58 0.15 1.1 0.42 0.72 0.54 0.28 0.34 0.15 1.1 0.52Hardness as CaCO3 (mg/l) 64 240 98 250 150 170 260 300 64 300 191.50Total Suspended Solids (mg/l) 338 66 944 495 654 1020 93 265 66 1020 484.38Oil and Grease (mg/l) <7 <7 <7 <7 7 <7 0 7 1.17 10Aluminum, dissolved (ug/l) 506 180 <3 3 3 6 <2 2 0 506 87.88 750Arsenic, dissolved (ug/l) 2 2 2 2 2 1 2.3 1.2 1 2.3 1.81 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.06 <.06 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 1.5 <1.0 <1 <1 0.11 0.17 0 1.5 0.35 7.1 0.3Chromium, dissolved (ug/l) 1 4.6 1.3 1.1 3.1 <1 <1 0.9 0 4.6 1.50 794 103Copper, dissolved (ug/l) 2 2.2 2.3 2.4 2.6 1.9 2.5 3.5 1.9 3.5 2.43 20 10Iron, dissolved (ug/l) 545 188 15 8 17 16 21 8 8 545 102.25 1000Lead, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.08 <.08 0 0 0.00 100 4Manganese, dissolved (ug/l) 54 232 133 265 100 125 95.5 345 54 345 168.69Mercury, total recoverable (ug/l) 0.1 <.1 <.1 <0.1 <0.1 <0.1 <1 0.02 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 1.3 2.9 3.1 3.2 2.8 1.6 2.48 5.47 1.3 5.47 2.86 660 73Selenium, dissolved (ug/l) <1 <1 <1 1 <1 2 1 1 0 2 0.62 5Silver, dissolved (ug/l) <1 <1 <1 <1.0 <1.0 <1.0 <.2 <.2 0 0 0.00 6.5Zinc, dissolved (ug/l) 37 49 2 <2 4 5 2 2.5 0 49 12.69 165 151Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 150 mg/l to 174 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-1MAXMINPARAMETER (units)MEAN WQ STANDARD*CREVE COEUR CREEK NEAR CREVE COEUR - WATER QUALITY ANALYSISUSGS SITE 06935890 WET WEATHER (FIRST FLUSH) RESULTS
APPENDIX A3-1WATER QUALITY ANALYSIS10/10/01 3/9/02 10/29/03 3/19/03 10/6/03 3/4/04 10/12/04 3/22/0509:24 04:42 07:14 12:47 16:12 13:31 20:02 14:52ACUTE CHRONICDischarge (CFS) 1640 189 641 761 1,510 1,420 339 1,150 189 1640 956.25pH (units) 7.8 7.4 7.7 7.7 7.5 7.4 7.7 7.8 7.4 7.8 7.63Temperature (deg. C) 17.1 11.8 11.4 13.1 18.6 9.4 15.3 6.9 6.9 18.6 12.95Dissolved Oxygen (mg/l) 7.1 1.1 7.6 5 6.4 10.7 6.1 11.7 1.1 11.7 6.96 5Fecal Coliform (col/100ml) 21500 38,000 10,500 22,000 2,700k 5,200 5200 38000 19440.00 200Fecal Streptococci (col/100ml) 20000 7,600 10,100 4,400 8,330 4400 20000 10086.00Ratio (Fec Coli/Fec Strep) 1.08 5.00 1.00 2.64 1 5 2.43Total Nitrogen as N (mg/l) 2.84 3.12 2.2 3.64 3.54 5.03 2.11 4.31 2.11 5.03 3.35Ammonia as N (mg/l) 0.05 0.25 0.01 0.26 0.08 0.4 0.06 0.24 0.01 0.4 0.17 8.92 1.08Total Phosphorus as P (mg/l) 1 0.2 0.54 0.68 1.2 2.2 0.4 1.69 0.2 2.2 0.99Hardness as CaCO3 (mg/l) 45 370 130 120 64 71 220 160 45 370 147.50Total Suspended Solids (mg/l) 861 134 409 611 1,290 1,930 182 1280d 134 1930 773.86Oil and Grease (mg/l) <7 <7 <7 <7 E3n <7 0 0 0.00 10Aluminum, dissolved (ug/l) 452 15 5 4 5 6 <2 3 0 452 61.25 750Arsenic, dissolved (ug/l) 2 4 <1 2 2 2 2.6 1.5 0 4 2.01 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <0.6 <0.6 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0.21 0.23 0 1 0.18 8.2 0.4Chromium, dissolved (ug/l) 1.1 6.4 <1.0 1.8 1.1 <1 <1 0.8 0 6.4 1.40 901 117Copper, dissolved (ug/l) 6.5 1.5 1.5 1.8 1.6 1.4 3 1.7 1.4 6.5 2.38 23 12Iron, dissolved (ug/l) 612 42 41 39 28 22 25 20 20 612 103.63 1000Lead, dissolved (ug/l) 2 <1 <1 <1 <1 <1 0.1 0.09 0 2 0.27 118 5Manganese, dissolved (ug/l) 67 1100 107 251 86 139 142 205 67 1100 262.13Mercury, total recoverable (ug/l) 0.1 <.1 <0.1 <0.1 <0.1 <0.1 0.01 0.05 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 1.7 4.6 1.8 2.8 1.6 1.5 4.67 3.85 1.5 4.67 2.82 752 84Selenium, dissolved (ug/l) <1 3 4 1 <1 2 1.2 1.1 0 4 1.54 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1.0 <1.0 <.2 5.9 0 5.9 0.74 8.4Zinc, dissolved (ug/l) 20 124 4 8 4 6 <.2 4.5 0 124 21.31 188 172Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 175 mg/l to 199 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-2PARAMETER (units)MIN MAX MEAN WQ STANDARD*USGS SITE 06936475 WET WEATHER (FIRST FLUSH) RESULTSCOLDWATER CREEK NEAR BLACK JACK - WATER QUALITY ANALYSIS
APPENDIX A3-1WATER QUALITY ANALYSIS10/5/01 2/19/02 10/25/02 3/19/03 10/9/03 3/4/04 10/12/04 3/22/0508:56 15:54 07:24 09:47 12:02 08:59 17:15 11:27ACUTE CHRONICDischarge (CFS) 161 210 130 178 509 302 137 188 130 509 226.88pH (units) 7.6 8 8 8.4 7.5 7.2 7.7 7.7 7.2 8.4 7.76Temperature (deg. C) 16.1 8.4 11.6 13.5 17.3 9 15.2 7.9 7.9 17.3 12.38Dissolved Oxygen (mg/l) 7.1 10.6 10.6 9.9 7.3 9.6 8.2 12 7.1 12 9.41 5Fecal Coliform (col/100ml) 29000 4,400 8,160 26,000 50,000 14,000k 1,200k 4400 50000 23512.00 200Fecal Streptococci (col/100ml) 13800 5800 1,500 9,170 22,500 5,600 1500 22500 9728.33Ratio (Fec Coli/Fec Strep) 2.10 2.93 0.89 1.16 8.93 0.89 8.93 3.20Total Nitrogen as N (mg/l) 1.25 1.56 0.87 2.4 2.4 2.63 1.52 1.06 0.87 2.63 1.71Ammonia as N (mg/l) 0.07 0.21 0.05 0.13 0.1 0.23 <0.4 0.05 0 0.23 0.11 8.92 1.08Total Phosphorus as P (mg/l) 0.28 0.2 0.17 0.39 0.76 0.54 0.28 0.17 0.17 0.76 0.35Hardness as CaCO3 (mg/l) 260 300 230 240 170 180 130 370 130 370 235.00Total Suspended Solids (mg/l) 190 307 114 596 1,400 741 92 122 92 1400 445.25Oil and Grease (mg/l) <7 3 <7 <7 <7 <1 0 3 0.50 10Aluminum, dissolved (ug/l) 54 164 <3 <3 5 5 3 <1 0 164 28.88 750Arsenic, dissolved (ug/l) 2 <1 2 2 2 1 1.4 0.9 0 2 1.41 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.06 <.06 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0.13 0.13 0 1 0.16 9.4 0.4Chromium, dissolved (ug/l) 1 <1 2.1 2.2 2.9 <1 1.7 0.8 0 2.9 1.34 1005 131Copper, dissolved (ug/l) 2 1.4 1.5 2.4 1.9 1.3 2.3 2.4 1.3 2.4 1.90 26 13Iron, dissolved (ug/l) 57 118 11 14 7 16 24 20 7 118 33.38 1000Lead, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.08 <1 0 0 0.00 136 5Manganese, dissolved (ug/l) 84 186 64 253 33 183 45.4 287 33 287 141.93Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 <1 <1 0 0 0.00 2.4 0.5Nickel, dissolved (ug/l) 1.5 1.5 2.2 3.4 2.3 1.6 2.34 5.75 1.5 5.75 2.57 842 94Selenium, dissolved (ug/l) <1 <1 <1 1 <1 3 0.4 0.8 0 3 0.65 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1 <1 <.2 <.2 0 0 0.00 10.6Zinc, dissolved (ug/l) 67 97 3 <2 2 7 2.4 3.9 0 97 22.79 211 193Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 200 mg/l to 224 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-3PARAMETER (units)MINUSGS SITE 07019185 WET WEATHER (FIRST FLUSH) RESULTSGRAND GLAIZE CREEK NEAR VALLEY PARK - WATER QUALITY ANALYSIS WQ STANDARD*MEANMAX
APPENDIX A3-1WATER QUALITY ANALYSIS10/24/01 3/9/02 10/29/02 4/16/03 10/9/03 3/4/04 10/26/04 3/22/0500:45 03:32 05:16 21:09 14:42 12:38 17:00 13:22ACUTE CHRONICDischarge (CFS) 61 171 180 416 541 709 127 398 61 709 325.38pH (units) 7.2 7.9 7.7 7.7 7.6 7.7 7.5 7.6 7.2 7.9 7.61Temperature (deg. C) 15.8 12.8 11.4 17.4 18.4 9.3 17.5 7.1 7.1 18.4 13.71Dissolved Oxygen (mg/l) 6 10.3 8.6 8.3 7.2 14.6 7.8 12.1 6 14.6 9.36 5Fecal Coliform (col/100ml) 10600 12,800 14,500 22,000 8,400 27,000k 8400 22000 13660.00 200Fecal Streptococci (col/100ml) 4000 14,700 21,000 25,000 10,000 4000 25000 14940.00Ratio (Fec Coli/Fec Strep) 0.87 0.69 0.88 0.69 0.88 0.81Total Nitrogen as N (mg/l) 1.31 2.34 1.5 5.4 3.3 4.08 2.04 3.84 1.31 5.4 2.98Ammonia as N (mg/l) 0.1 0.03 <0.01 0.18 0.07 0.14 <.04 0.28 0 0.28 0.10 8.92 1.08Total Phosphorus as P (mg/l) 0.27 0.57 0.48 1.6 1.3 2.1 0.92 1.22 0.27 2.1 1.06Hardness as CaCO3 (mg/l) 160 240 120 170 66 83 110 120 66 240 133.63Total Suspended Solids (mg/l) 69 575 305 2,300 1,300 2,190 465d 872d 69 2300 1123.17Oil and Grease (mg/l) <7 <7 <7 <7 <1 <7 0 0 0.00 10Aluminum, dissolved (ug/l) 206 185 4 <3 5 8 3 15 0 206 53.25 750Arsenic, dissolved (ug/l) 2 2 1 2 2 2 1.8 1.3 1 2 1.76 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.06 <.06 0 0 0.00 5Cadmium, dissolved (ug/l) 0.3 <1 <1 <1 <1 <1 <1 <1 0 0.3 0.04 7.1 0.3Chromium, dissolved (ug/l) 0.6 3.3 <1 2.8 1.4 <1 <.8 0.9 0 3.3 11.25 794 103Copper, dissolved (ug/l) 4.5 3.8 1.4 2.8 2 2.2 1.7 1.3 1.3 4.5 2.46 20 10Iron, dissolved (ug/l) 312 163 20 21 21 18 47 38 18 312 80.00 1000Lead, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0.16 0.14 0 0.16 0.04 100 4Manganese, dissolved (ug/l) 232 409 95 452 75 93 251 218 75 452 228.13Mercury, total recoverable (ug/l) <.1 <.1 <0.1 0.1 <0.1 <0.1 0.04 0.04 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 3.2 3.2 1.5 4.2 1.6 1.8 2.42 3.01 1.5 4.2 2.62 660 73Selenium, dissolved (ug/l) <1 1 <1 <1 <1 2 0.5 0.6 0 2 0.51 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.2 <.2 0 0 0.00 6.5Zinc, dissolved (ug/l) 94 25 4 13 3 7 4.3 4.3 3 94 19.33 165 151Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 150 mg/l to 174 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-4MAXUSGS SITE 07005000 WET WEATHER (FIRST FLUSH) RESULTSMALINE CREEK AT BELLEFONTAINE NEIGHBORS - WATER QUALITY ANALYSIS WQ STANDARD*PARAMETER (units)MIN MEAN
APPENDIX A3-1WATER QUALITY ANALYSIS10/24/01 3/9/02 10/29/02 3/19/03 10/9/03 3/3/04 10/12/04 3/22/0513:22 02:17 01:56 08:52 13:37 20:21 16:14 09:49ACUTE CHRONICDischarge (CFS) 593 157 15 161 691 68 177 109 15 691 246.38pH (units) 7.5 7.6 7.3 7.8 7 7.6 7.3 7.8 7 7.8 7.49Temperature (deg. C) 13.6 14.2 12.3 14.3 18.8 9.9 15.8 6.4 6.4 18.8 13.16Dissolved Oxygen (mg/l) 8.9 7.7 7 9.4 8.6 9.2 7 12.3 7 12.3 8.76 5Fecal Coliform (col/100ml) 56000 32,000 22,000 100,000 33,000 22000 100000 48600.00 200Fecal Streptococci (col/100ml) 134000 27,000 14,000 76,000 14000 134000 62750.00Ratio (Fec Coli/Fec Strep) 1.2 1.6 1.2 1.6 1.40Total Nitrogen as N (mg/l) 2.23 5.43 4.40 5.40 2.93 8.7 5.13 7.12d 2.23 8.7 4.89Ammonia as N (mg/l) 0.21 0.23 1.3 0.87 0.1 0.94 0.24 0.51 0.1 1.3 0.55 8.92 1.08Total Phosphorus as P (mg/l) 0.86 0.93 0.79 0.76 0.8 1.6 1.24 1.24 0.76 1.6 1.03Hardness as CaCO3 (mg/l) 35 140 83 110 37 150 61 120 35 150 92.00Total Suspended Solids (mg/l) 633 380 159 322 784 721 383 375d 159 784 483.14Oil and Grease (mg/l) 18 5 <7 <7 <1 16 0 18 6.50 10Aluminum, dissolved (ug/l) 188 245 7 8 13 8 9 9 7 245 60.88 750Arsenic, dissolved (ug/l) 1 2 <1 2 2 2 1.4 0.9 0 2 1.41 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.06 <.06 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1 <1 <1 <1 <1 0.06 0 1 0.13 3.6 0.2Chromium, dissolved (ug/l) 1.3 3.1 <1 2.6 1.9 <1 <1 2.8 0 3.1 1.46 450 59Copper, dissolved (ug/l) 5.2 6.8 1.6 2.6 3.9 2 2.5 3.2 1.6 6.8 3.48 10 6Iron, dissolved (ug/l) 330 252 78 32 25 60 88 31 25 330 112.00 1000Lead, dissolved (ug/l) 5 2 <1 <1 <1 <1 0.39 0.2 0 5 0.95 47 2Manganese, dissolved (ug/l) 84 363 207 137 29 566 224 216 29 566 228.25Mercury, total recoverable (ug/l) 0.1 <.1 <0.1 <0.1 <0.1 <0.1 .37d 0.04 0 0.1 0.06 2.4 0.5Nickel, dissolved (ug/l) 1.7 3.1 1.3 2.7 1.5 2.6 1.76 3.59 1.3 3.59 2.28 367 41Selenium, dissolved (ug/l) <1 1 1 1 <1 3 0.6 0.9 0 3 0.94 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <.2 <.2 0 0 0.00 2Zinc, dissolved (ug/l) 91 137 11 28 8 13 6.9 9.5 6.9 137 38.05 92 84Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 75 mg/l to 99 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-5PARAMETER (units)MIN WQ STANDARD*MEANMAXRIVER DES PERES NEAR UNIVERSITY CITY - WATER QUALITY ANALYSISUSGS SITE 07010022 WET WEATHER (FIRST FLUSH) RESULTS
APPENDIX A3-1WATER QUALITY ANALYSIS10/10/01 3/25/02 10/2/02 3/13/03 10/17/03 3/4/0406:30 05:42 23:30 04:14 00:53 10:59ACUTE CHRONICDischarge (CFS) 57 109 128 88 54 151 54 151 97.83pH (units) 7.8 7.7 7.1 21 7.7 7.7 7.1 21 9.83Temperature (deg. C) 14.9 5.7 21 10.6 13.7 9.2 5.7 21 12.52Dissolved Oxygen (mg/l) 8.1 10.8 7.1 8.9 8.4 9 7.1 10.8 8.72 5Fecal Coliform (col/100ml) 4000 1100 27,600 667 26,000 8,170 667 27600 11256.17 200Fecal Streptococci (col/100ml) 17000 4950 48,000 2,500 4,200 2500 48000 15330.00Ratio (Fec Coli/Fec Strep) 0.24 0.22 0.57 0.27 1.94 0.22 1.94 0.65Total Nitrogen as N (mg/l) 1.97 2.99 4.8 2.1 1.83 1.51 1.51 4.8 2.53Ammonia as N (mg/l) 0.06 0.28 0.08 0.1 0.04 0.08 0.04 0.28 0.11 8.92 1.08Total Phosphorus as P (mg/l) 0.5 0.49 2.1 0.47 0.36 0.44 0.36 2.1 0.73Hardness as CaCO3 (mg/l) 180 120 100 130 190 160 100 190 146.67Total Suspended Solids (mg/l) 293 100 2,420 297 116 528 100 2420 625.67Oil and Grease (mg/l) <7 <7 <7 <7 <7 <7 0 0 0.00 10Aluminum, dissolved (ug/l) 205 388 7 4 <3 8 0 388 76.50 750Arsenic, dissolved (ug/l) 2 1 2 2 2 2 1 2 1.83 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0 1 0.13 7.1 0.3Chromium, dissolved (ug/l) 1 <1 1.4 <1.0 4.1 <1 0 4.1 0.81 794 103Copper, dissolved (ug/l) 1.7 2.4 2.9 1.8 2.5 1.2 1.2 2.9 2.08 20 10Iron, dissolved (ug/l) 241 352 5 30 22 17 5 352 111.17 1000Lead, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 100 4Manganese, dissolved (ug/l) 78 106 9 97 95 139 9 139 87.33Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0 0.00 2.4 0.5Nickel, dissolved (ug/l) 1.7 2 2.9 2.2 3.3 1.3 1.3 3.3 2.23 660 73Selenium, dissolved (ug/l) <1 <1 <1 <1 <1 3 0 3 0.38 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1 <1 0 0 0.00 6.5Zinc, dissolved (ug/l) 42 102 <2 2 4 7 0 102 19.62 165 151Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 150 mg/l to 174 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-6MINPARAMETER (units) WQ STANDARD*USGS SITE 06935770 WET WEATHER (FIRST FLUSH) RESULTSBONHOMME CREEK NEAR CLARKSON VALLEY - WATER QUALITY ANALYSISMEANMAX
APPENDIX A3-1WATER QUALITY ANALYSIS10/5/01 3/25/02 10/18/02 3/28/03 10/9/03 3/4/0405:55 00:38 0.858333 0.5416667 10:19 08:50ACUTE CHRONICDischarge (CFS) 27 40 59 29 28 36 27 59 36.50pH (units) 7.6 7.9 7.7 8.1 7.6 7.5 7.5 8.1 7.73Temperature (deg. C) 14.7 4.3 15.5 10 18.6 9.6 4.3 18.6 12.12Dissolved Oxygen (mg/l) 8.3 11.5 8.6 10 7.1 10.5 7.1 11.5 9.33 5Fecal Coliform (col/100ml) 32000 3200 86,000 10,800 12,000 3200 86000 28800.00 200Fecal Streptococci (col/100ml) 5600 12,400 4,600 15,000 4600 15000 9400.00Ratio (Fec Coli/Fec Strep) 5.71 6.9 2.34 0.80 0.8 6.9 3.94Total Nitrogen as N (mg/l) 3.45 2.6 2.83 2.17 2.62 2.29 2.17 3.45 2.66Ammonia as N (mg/l) 0.2 0.27 0.11 0.06 0.02 0.09 0.02 0.27 0.13 8.92 1.08Total Phosphorus as P (mg/l) 0.55 0.18 0.72 0.24 0.38 0.57 0.18 0.72 0.44Hardness as CaCO3 (mg/l) 200 200 190 360 260 160 160 360 228.33Total Suspended Solids (mg/l) 170 74 579 147 207 605 74 605 297.00Oil and Grease (mg/l) <7 <7 <7 <7 <7 8 0 8 13.33 10Aluminum, dissolved (ug/l) 48 71 5 25 5 821 5 821 162.50 750Arsenic, dissolved (ug/l) 2 2 1 2 2 1 1 2 1.67 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0 1 0.17 9.4 0.4Chromium, dissolved (ug/l) 1.1 2.4 <1.0 8.4 3.9 4.9 1.1 8.4 4.14 1005 131Copper, dissolved (ug/l) 3.7 4 2.4 4.4 4.2 11 2.4 11 4.95 26 13Iron, dissolved (ug/l) 116 87 13 20 14 1,310 13 1310 260.00 1000Lead, dissolved (ug/l) <1 <1 <1 <1 <1 7 0 7 1.17 136 5Manganese, dissolved (ug/l) 127 316 165 432 148 300 127 432 248.00Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0 0.00 2.4 0.5Nickel, dissolved (ug/l) 2.7 2.6 2.1 5.4 3.8 3.6 2.1 5.4 3.37 842 94Selenium, dissolved (ug/l) <1 <1 1 2 1 2 0 2 1.00 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1 <1 0 0 0.00 10.6Zinc, dissolved (ug/l) 76 87 8 14 15 45 8 87 40.83 211 193Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 200 mg/l to 224 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-7USGS SITE 06935980 WET WEATHER (FIRST FLUSH) RESULTS WQ STANDARD*MEANPARAMETER (units)MAXMINCOWMIRE CREEK AT BRIDGETONE - WATER QUALITY ANALYSIS
APPENDIX A3-1WATER QUALITY ANALYSIS10/5/01 3/9/02 10/25/02 3/28/03 10/9/03 3/3/0409:54 03:27 06:32 14:47 13:27 21:26ACUTE CHRONICDischarge (CFS) 247 392 143 118 1,100 98 98 1100 349.67pH (units) 7.5 6.3 7.6 7.3 7.7 7.5 6.3 7.7 7.32Temperature (deg. C) 15.8 14 13.1 11.4 18 10.5 10.5 18 13.80Dissolved Oxygen (mg/l) 7.2 8.5 7.2 10.6 5.8 8.7 5.8 10.6 8.00 5Fecal Coliform (col/100ml) 59000 49000 55,000 26,000 31,000k 26000 59000 47250.00 200Fecal Streptococci (col/100ml) 77000 16200 11,700 3,700 18,000 4,400 3700 77000 21833.33Ratio (Fec Coli/Fec Strep) 0.77 3.02 4.70 7.00 1.72 0.77 7 3.44Total Nitrogen as N (mg/l) 2.49 3.2 3.65 2.16 3.68 2.54 2.16 3.68 2.95Ammonia as N (mg/l) 0.55 0.24 1.5 0.33 0.3 0.33 0.24 1.5 0.54 8.92 1.08Total Phosphorus as P (mg/l) 0.37 0.65 0.41 0.22 0.82 0.26 0.22 0.82 0.46Hardness as CaCO3 (mg/l) 64 150 140 170 91 240 64 240 142.50Total Suspended Solids (mg/l) 133 337 114 27 378 135 27 378 187.33Oil and Grease (mg/l) <7 5 <7 <7 <1 <7 0 5 0.83 10Aluminum, dissolved (ug/l) 141 372 6 7 4 7 4 372 89.50 750Arsenic, dissolved (ug/l) 2 3 2 2 2 2 2 3 2.17 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0 1 0.17 5.9 0.3Chromium, dissolved (ug/l) 1.4 2.6 1.2 5.5 2.5 1.7 1.2 5.5 2.48 684 89Copper, dissolved (ug/l) 5.7 5.4 3.4 5.4 3.7 3.7 3.4 5.7 4.55 17 9Iron, dissolved (ug/l) 201 265 58 42 25 21 21 265 102.00 1000Lead, dissolved (ug/l) 1 2 <1 <1 <1 <1 0 2 0.50 82 3Manganese, dissolved (ug/l) 69 191 165 222 81 384 69 384 185.33Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0 0.00 2.4 0.5Nickel, dissolved (ug/l) 1.2 2.9 2.6 3.6 2 2.2 1.2 3.6 2.42 566 63Selenium, dissolved (ug/l) <1 <1 <1 1 <1 4 0 4 0.83 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1 <1 0 0 0.00 4.7Zinc, dissolved (ug/l) 30 134 23 27 5 15 5 134 39.00 142 129Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 125 mg/l to 149 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-8 WQ STANDARD*MEANMIN MAXPARAMETER (units)USGS SITE 07010086 WET WEATHER (FIRST FLUSH) RESULTSDEER CREEK AT MAPLEWOOD - WATER QUALITY ANALYSIS
APPENDIX A3-1WATER QUALITY ANALYSIS10/24/01 4/8/02 10/25/02 4/20/03 10/9/03 3/4/0413:20 07:11 07:25 04:15 11:47 09:16ACUTE CHRONICDischarge (CFS) 44 22 11 20 34 45 11 45 29.33pH (units) 7.5 7.7 7.8 7.2 8.3 7.9 7.2 8.3 7.73Temperature (deg. C) 15.1 10.8 12.3 15.1 18 14.5 10.8 18 14.30Dissolved Oxygen (mg/l) 8.1 8.5 9.1 8.4 7.5 8.9 7.5 9.1 8.42 5Fecal Coliform (col/100ml) 17000 9200 8,200 12,000 22,000 8,800 8200 22000 12866.67 200Fecal Streptococci (col/100ml) 20500 7200 28,000 14,000 32,000 4,800 4800 32000 17750.00Ratio (Fec Coli/Fec Strep) 0.83 1.28 0.29 0.86 0.69 1.83 0.29 1.83 0.96Total Nitrogen as N (mg/l) 1.97 1.72 2.03 2.94 3.02 6.94 1.72 6.94 3.10Ammonia as N (mg/l) 0.03 0.16 0.03 0.04 0.12 0.14 0.03 0.16 0.09 8.92 1.08Total Phosphorus as P (mg/l) 0.77 0.27 0.51 0.64 0.74 1.7 0.27 1.7 0.77Hardness as CaCO3 (mg/l) 54 92 64 130 58 59 54 130 76.17Total Suspended Solids (mg/l) 825 169 213 255 697 1,990 169 1990 691.50Oil and Grease (mg/l) 3 <7 <7 <7 <7 <7 0 3 0.50 10Aluminum, dissolved (ug/l) 285 425 6 5 36 8 5 425 127.50 750Arsenic, dissolved (ug/l) 1 1 1 <1 1 1 0 1 0.83 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0 1 0.17 3.6 0.2Chromium, dissolved (ug/l) 1.3 1.4 <1.0 <1.0 1.8 <1 0 1.8 0.75 450 59Copper, dissolved (ug/l) 6.6 4.8 3.8 5 3.7 4.7 3.7 6.6 4.77 10 6Iron, dissolved (ug/l) 483 327 38 26 20 15 15 483 151.50 1000Lead, dissolved (ug/l) 10 2 <1 <1 <1 <1 0 10 2.00 47 2Manganese, dissolved (ug/l) 94 98 45 88 28 73 28 98 71.00Mercury, total recoverable (ug/l) 0.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 3 1.5 1.7 2.5 1.6 1.2 1.2 3 1.92 367 41Selenium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1 <1 0 0 0.00 2Zinc, dissolved (ug/l) 32 159 9 12 5 4 4 159 36.83 92 84Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 75 mg/l to 99 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-9 WQ STANDARD*MAXMIN MEANPARAMETER (units)USGS SITE 07010035 WET WEATHER (FIRST FLUSH) RESULTSENGLEHOLM CREEK NEAR WELLSTON - WATER QUALITY ANALYSIS
APPENDIX A3-1WATER QUALITY ANALYSIS10/23/013/19/02 10/18/02 4/6/03 10/9/03 3/4/0421:0004:41 21:03 08:38 10:07 06:48ACUTE CHRONICDischarge (CFS) 132 49 59 4 69 51 4 132 60.67pH (units) 7.4 7.9 7.7 7.8 7.5 7.7 7.4 7.9 7.67Temperature (deg. C) 17.5 8.8 15.3 7.4 18.3 9.5 7.4 18.3 12.80Dissolved Oxygen (mg/l) 6.4 8.3 7.8 9.8 7.5 10.1 6.4 10.1 8.32 5Fecal Coliform (col/100ml) 4400 380 7,000 4,400 71,000 380 71000 17436.00 200Fecal Streptococci (col/100ml) 1020 10,800 1,750 1020 10800 4523.33Ratio (Fec Coli/Fec Strep) 0.37 0.65 2.50 0.37 2.5 1.17Total Nitrogen as N (mg/l) 2.49 1.98 1.6 1.22 2.37 1.92 1.22 2.49 1.93Ammonia as N (mg/l) 0.24 0.1 0.1 0.03 0.17 0.07 0.03 0.24 0.12 8.92 1.08Total Phosphorus as P (mg/l) 0.92 0.17 0.29 0.2 0.69 0.19 0.17 0.92 0.41Hardness as CaCO3 (mg/l) 150 260 250 330 290 230 150 330 251.67Total Suspended Solids (mg/l) 1080 48 127 143 584 119 48 1080 350.17Oil and Grease (mg/l) <7 <7 <7 <7 <1 <1 0 0 0.00 10Aluminum, dissolved (ug/l) 148 60 31 <3 <3 285 0 285 87.33 750Arsenic, dissolved (ug/l) 2 2 <1 7 4 2 0 7 2.83 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1.0 <1.0 <1 <1 0 1 0.17 10.5 0.4Chromium, dissolved (ug/l) 1 4.2 1 2.3 4.1 1.8 1 4.2 2.40 1107 144Copper, dissolved (ug/l) 2.7 4.6 2.8 2.3 2.5 4.5 2.3 4.6 3.23 29 15Iron, dissolved (ug/l) 326 91 54 25 11 407 11 407 152.33 1000Lead, dissolved (ug/l) 1 <1 <1 <1 <1 2 0 2 0.50 154 6Manganese, dissolved (ug/l) 224 472 124 310 324 361 124 472 302.50Mercury, total recoverable (ug/l) 0.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 3.3 4.7 2.8 6.4 6 3.4 2.8 6.4 4.43 930 103Selenium, dissolved (ug/l) <1 1 <1 2 2 4 0 4 1.50 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1.0 <1.0 0 0 0.00 13Zinc, dissolved (ug/l) 46 111 14 8 7 22 7 111 34.67 233 213Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 225 mg/l to 249 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-10USGS SITE 06935955 WET WEATHER (FIRST FLUSH) RESULTSFEE FEE CREEK NEAR BRIDGETON - WATER QUALITY ANALYSIS WQ STANDARD*MIN MAX MEANPARAMETER (units)
APPENDIX A3-1WATER QUALITY ANALYSIS10/15/01 2/19/02 10/25/02 3/13/03 10/9/03 3/26/0420:30 15:22 08:30 02:57 13:47 11:22ACUTE CHRONICDischarge (CFS) 92 97 160 138 94 125 92 160 117.67pH (units) 6.7 7.7 7.8 7.8 7.5 7.7 6.7 7.8 7.53Temperature (deg. C) 12.2 9.9 12.6 11.9 18.2 14.6 9.9 18.2 13.23Dissolved Oxygen (mg/l) 8.4 9.9 8.7 10.1 7 8.9 7 10.1 8.83 5Fecal Coliform (col/100ml) 15,800 2,670 38,500 2670 38500 18990.00 200Fecal Streptococci (col/100ml) 29000 24,000 6,200 6,800 8,000 6200 29000 14800.00Ratio (Fec Coli/Fec Strep) 0.66 0.43 4.81 0.43 4.81 1.97Total Nitrogen as N (mg/l) <.72 1.78 2.74 2.81 2.08 2.39 0 2.81 1.97Ammonia as N (mg/l) 0.03 0.05 0.08 0.13 0.06 0.12 0.03 0.13 0.08 8.92 1.08Total Phosphorus as P (mg/l) 0.3 0.26 0.57 0.49 0.35 0.34 0.26 0.57 0.39Hardness as CaCO3 (mg/l) 140 150 92 150 130 170 92 170 138.67Total Suspended Solids (mg/l) 336 336 1,070 385 288 307 288 1070 453.67Oil and Grease (mg/l) <7 4 <7 <7 <7 <7 0 4 0.67 10Aluminum, dissolved (ug/l) 350 1210 11 5 <3 5 0 1210 263.50 750Arsenic, dissolved (ug/l) 1 <1 1 1 2 <1 0 2 0.83 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) <1 <1 <1.0 <1.0 <1 <1 0 0 0.00 7.1 0.3Chromium, dissolved (ug/l) 1.1 1.1 <1.0 1.7 2.7 1.6 0 2.7 1.37 794 103Copper, dissolved (ug/l) 2.7 1.8 2 2.3 2.5 2.1 1.8 2.7 2.23 20 10Iron, dissolved (ug/l) 365 761 22 23 11 9 9 761 198.50 1000Lead, dissolved (ug/l) 1 <1 <1 <1 <1 <1 0 1 0.17 100 4Manganese, dissolved (ug/l) 108 103 21 56 11 109 11 109 68.00Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0 0.00 2.4 0.5Nickel, dissolved (ug/l) 2.2 1.3 2.3 2.4 2.5 1.4 1.3 2.5 2.02 660 73Selenium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Silver, dissolved (ug/l) <1 <1 <1.0 <1.0 <1.0 <1.0 0 0 0.00 6.5Zinc, dissolved (ug/l) 109 52 2 6 3 5 2 109 29.50 165 151Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 150 mg/l to 174 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-11MEANPARAMETER (units) WQ STANDARD*FENTON CREEK NEAR FENTON - WATER QUALITY ANALYSISMINUSGS SITE 07019220 WET WEATHER (FIRST FLUSH) RESULTSMAX
APPENDIX A3-1WATER QUALITY ANALYSIS10/10/013/9/02 10/25/02 3/19/03 10/9/03 3/4/0407:1504:26 08:55 11:12 13:29 09:06ACUTE CHRONICDischarge (CFS) 808 89 6.1 54 e 41 6.1 808 199.62pH (units) 8 7.6 7.8 7.8 7.2 7.5 7.2 8 7.65Temperature (deg. C) 16.9 12.1 12.5 12.9 18 8.6 8.6 18 13.50Dissolved Oxygen (mg/l) 7.5 9.25 8.9 10.7 7.7 10.5 7.5 10.7 9.09 5Fecal Coliform (col/100ml) 60000 9000 39,000 6,200 28,500 39,500 6200 60000 30366.67 200Fecal Streptococci (col/100ml) 39200 11600 20,800 12,000 22,500 11600 39200 21220.00Ratio (Fec Coli/Fec Strep) 1.53 0.78 1.90 0.52 1.27 0.52 1.9 1.20Total Nitrogen as N (mg/l) 4.18 2.74 2.07 2.85 2.26 2.8 2.07 4.18 2.82Ammonia as N (mg/l) 0.04 0.11 0.05 0.15 0.06 0.16 0.04 0.16 0.10 8.92 1.08Total Phosphorus as P (mg/l) 1.2 0.6 0.51 0.4 0.94 0.55 0.4 1.2 0.70Hardness as CaCO3 (mg/l) 45 150 66 87 60 100 45 150 84.67Total Suspended Solids (mg/l) 2160 594 459 228 958 667 228 2160 844.33Oil and Grease (mg/l) <7 <7 <7 <7 <1 <7 0 0 0.00 10Aluminum, dissolved (ug/l) 1060 274 5 5 4 509 4 1060 309.50 750Arsenic, dissolved (ug/l) 2 2 <1 2 1 2 0 2 1.50 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1 <1 <1 <1 1 1 0.17 3.6 0.2Chromium, dissolved (ug/l) 1 2.6 <1.0 2.7 2 1.3 0 2.7 1.60 450 59Copper, dissolved (ug/l) 2.5 2.3 2 3.9 2.9 3.2 2 3.9 2.80 10 6Iron, dissolved (ug/l) 997 170 16 20 10 506 10 997 286.50 1000Lead, dissolved (ug/l) 2 <1 <1 <1 <1 2 0 2 0.67 47 2Manganese, dissolved (ug/l) 52 50 24 86 5 61 5 86 46.33Mercury, total recoverable (ug/l) 0.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 1.5 2.4 1.1 1.9 1.6 2.7 1.1 2.7 1.87 367 41Selenium, dissolved (ug/l) <1 <1 <1 <1 <1 2 0 2 0.33 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1.0 <1.0 0 0 0.00 2Zinc, dissolved (ug/l) 34 95 3 3 2 7 2 95 24.00 92 84Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 75 mg/l to 99 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-12MIN WQ STANDARD*FISHPOT CREEK AT VALLEY PARK - WATER QUALITY ANALYSISUSGS SITE 07019120 WET WEATHER (FIRST FLUSH) RESULTSMAX MEANPARAMETER (units)
APPENDIX A3-1WATER QUALITY ANALYSIS10/15/01 3/9/02 10/3/02 4/4/03 10/9/03 3/3/0420:25 03:16 03:30 16:28 13:08 21:22ACUTE CHRONICDischarge (CFS) 115 297 191 133 278 85 85 297 183.17pH (units) 7.5 7.7 7.5 7.5 7.6 7.8 7.5 7.8 7.60Temperature (deg. C) 11.7 13.6 22.4 17.6 18.5 9.5 9.5 22.4 15.55Dissolved Oxygen (mg/l) 10.1 9.1 5.8 7.6 8.4 8.1 5.8 10.1 8.18 5Fecal Coliform (col/100ml) 38000 7800 7,430 6,600 46,000 25,000 6600 46000 21805.00 200Fecal Streptococci (col/100ml) 34000 5800 5,800 2,600 49,000 2600 49000 19440.00Ratio (Fec Coli/Fec Strep) 1.12 1.34 1.28 2.54 0.94 0.94 2.54 1.44Total Nitrogen as N (mg/l) <.72 2.79 2.54 3.15 2.1 1.69 0 3.15 2.05Ammonia as N (mg/l) 0.02 0.07 0.13 0.19 0.13 0.06 0.02 0.19 0.10 8.92 1.08Total Phosphorus as P (mg/l) 0.29 0.68 0.51 0.44 0.32 0.22 0.22 0.68 0.41Hardness as CaCO3 (mg/l) 91 190 210 170 210 200 91 210 178.50Total Suspended Solids (mg/l) 118 982 778 325 790 231 118 982 537.33Oil and Grease (mg/l) <7 <7 <7 <7 <7 <1 0 0 0.00 10Aluminum, dissolved (ug/l) 252 671 <3 5 <3 5 0 671 155.50 750Arsenic, dissolved (ug/l) 1 3 1 7 2 1 1 7 2.50 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 7.1 0.3Chromium, dissolved (ug/l) 1.2 3.6 2.2 4.5 3.8 1.4 1.2 4.5 2.78 794 103Copper, dissolved (ug/l) 2.9 2.8 2.3 4.5 3.3 3.1 2.3 4.5 3.15 20 10Iron, dissolved (ug/l) 285 463 6 28 8 16 6 463 134.33 1000Lead, dissolved (ug/l) 2 1 <1 <1 <1 <1 0 2 0.50 100 4Manganese, dissolved (ug/l) 72 148 49 211 100 125 49 211 117.50Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 0 0 0.00 2.4 0.5Nickel, dissolved (ug/l) 1.5 2.9 2.3 4.2 3.5 1.5 1.5 4.2 2.65 660 73Selenium, dissolved (ug/l) <1 1 <1 1 1 4 0 4 1.17 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 6.5Zinc, dissolved (ug/l) 32 103 4 13 7 10 4 103 28.17 165 151Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 150 mg/l to 174 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-13MEANPARAMETER (units)MAX WQ STANDARD*MINGRAVOIS CREEK NEAR MEHLVILLE - WATER QUALITY ANALYSISUSGS SITE 07010180 WET WEATHER (FIRST FLUSH) RESULTS
APPENDIX A3-1WATER QUALITY ANALYSIS10/10/01 10/25/02 3/19/03 10/9/03 3/4/0407:44 08:27 10:52 12:42 10:07ACUTE CHRONICDischarge (CFS) 108 62 46 86 27 27 108 65.80pH (units) 7.4 7.2 7.4 7.3 7.2 7.2 7.4 7.30Temperature (deg. C) 16.5 12.9 13 17.4 10 10 17.4 13.96Dissolved Oxygen (mg/l) 9 10.5 10.7 8.5 10 8.5 10.7 9.74 5Fecal Coliform (col/100ml) 34000 28,000 18,300 44,000 18300 44000 31075.00 200Fecal Streptococci (col/100ml) 24800 6,800 14,000 49,000 6800 49000 23650.00Ratio (Fec Coli/Fec Strep) 1.37 4.12 1.31 0.90 0.9 4.12 1.93Total Nitrogen as N (mg/l) 2.47 2.24 1.8 3.82 2.00 1.8 3.82 2.47Ammonia as N (mg/l) 0.14 0.07 0.1 0.09 0.03 0.03 0.14 0.09 8.92 1.08Total Phosphorus as P (mg/l) 0.56 0.45 0.42 0.9 0.23 0.23 0.9 0.51Hardness as CaCO3 (mg/l) 85 110 140 65 180 65 180 116.00Total Suspended Solids (mg/l) 315 225 334 1,250 279 225 1250 480.60Oil and Grease (mg/l) 5 <7 <7 <7 <7 0 5 1.00 10Aluminum, dissolved (ug/l) 736 4 4 6 6 4 736 151.20 750Arsenic, dissolved (ug/l) 2 <1 1 1 <1 0 2 0.80 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1 <1 <1 0 1 0.20 4.8 0.3Chromium, dissolved (ug/l) 1 1.3 1.4 2 <1 0 2 1.14 570 74Copper, dissolved (ug/l) 2.8 1.6 2.3 2.5 <1 0 2.8 1.84 13 7Iron, dissolved (ug/l) 516 9 16 12 6 6 516 111.80 1000Lead, dissolved (ug/l) <1 <1 <1 <1 <1 0 0 0.00 65 3Manganese, dissolved (ug/l) 31 12 42 5 48 5 48 27.60Mercury, total recoverable (ug/l) 0.1 <0.1 <0.1 <0.1 <0.1 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 1.5 1.3 1.7 1.5 1 1 1.7 1.40 469 52Selenium, dissolved (ug/l) <1 <1 <1 <1 3 0 3 0.60 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1 0 0 0.00 3.2Zinc, dissolved (ug/l) 55 2 3 2 5 2 55 13.40 117 107Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 100 mg/l to 124 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-14 WQ STANDARD*USGS SITE 07019072 WET WEATHER (FIRST FLUSH) RESULTSMIN MAX MEANPARAMETER (units)KIEFER CREEK NEAR BALLWIN - WATER QUALITY ANALYSIS
APPENDIX A3-1WATER QUALITY ANALYSIS10/15/01 3/9/02 10/19/02 4/16/03 10/9/2003 3/3/200419:43 02:26 03:45 20:10 12:56 20:27ACUTE CHRONICDischarge (CFS) 121 107 121 236 709 110 107 709 234.00pH (units) 6.9 7.7 7.6 7.7 7.7 7.7 6.9 7.7 7.55Temperature (deg. C) 13.2 13.5 14.5 17.4 18.4 9.5 9.5 18.4 14.42Dissolved Oxygen (mg/l) 8.7 9.5 7.7 8.7 7.8 6.5 6.5 9.5 8.15 5Fecal Coliform (col/100ml) 5400 13,800 4,400 58,000 4,800 4400 58000 17280.00 200Fecal Streptococci (col/100ml) 7000 11,500 2,850 60,000 8,830 2850 60000 18036.00Ratio (Fec Coli/Fec Strep) 0.77 1.2 1.54 0.97 0.54 0.54 1.54 1.00Total Nitrogen as N (mg/l) <.79 3.72 2.1 5.4 3.02 2.94 0 5.4 2.86Ammonia as N (mg/l) 0.01 0.13 0.03 0.15 0.13 0.08 0.01 0.15 0.09 8.92 1.08Total Phosphorus as P (mg/l) 0.22 0.72 0.44 0.89 0.71 0.5 0.22 0.89 0.58Hardness as CaCO3 (mg/l) 210 140 60 84 88 120 60 210 117.00Total Suspended Solids (mg/l) 121 803 421 1,420 829 584 121 1420 696.33Oil and Grease (mg/l) <7 <7 <7 <7 <7 <1 0 0 0.00 10Aluminum, dissolved (ug/l) 151 401 6 6 6 5 5 401 95.83 750Arsenic, dissolved (ug/l) 1 2 <1 1 2 <1 0 2 1.00 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 5.9 0.3Chromium, dissolved (ug/l) <1 3.2 <1 3.9 3.4 2.5 0 3.9 2.17 684 89Copper, dissolved (ug/l) 2.6 3.3 1.6 2.8 4.3 2 1.6 4.3 2.77 17 9Iron, dissolved (ug/l) 164 244 15 28 13 8 8 244 78.67 1000Lead, dissolved (ug/l) <1 1 <1 <1 <1 <1 0 1 0.17 82 3Manganese, dissolved (ug/l) 55 82 6 119 16 67 6 119 57.50Mercury, total recoverable (ug/l) <.1 <.1 0.1 0.1 <0.1 <0.1 0 0.1 0.03 2.4 0.5Nickel, dissolved (ug/l) 1.7 2.4 <1 2.4 2 1.4 0 2.4 1.65 560 63Selenium, dissolved (ug/l) 2 <1 <1 <1 1 3 0 3 1.00 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1 <1 0 0 0.00 4.7Zinc, dissolved (ug/l) 140 108 3 11 4 9 3 140 45.83 142 129Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 125 mg/l to 149 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-15PARAMETER (units) WQ STANDARD*MIN MAX MEANMATTESE CREEK NEAR MATTESE- WATER QUALITY ANALYSISUSGS SITE 07019317 WET WEATHER (FIRST FLUSH) RESULTS
APPENDIX A3-1WATER QUALITY ANALYSIS10/23/01 3/9/02 10/29/02 3/28/03 10/14/03 10/14/03 3/26/04 3/26/0423:57 06:17 06:16 14:33 04:42 04:43 09:54 09:55ACUTE CHRONICDischarge (CFS) 12 158 54 34 30 57 12 158 57.50pH (units) 7.8 7.5 7.5 7.9 7.5 7.5 7.7 7.5 7.9 7.63Temperature (deg. C) 16.2 12.7 11.3 10.3 15.8 14.5 14.5 10.3 16.2 13.61Dissolved Oxygen (mg/l) 6.3 9.8 8.8 10.3 6.6 9.2 9.2 6.3 10.3 8.60 5Fecal Coliform (col/100ml) 42000 16500 48,000 14,500 3,700 14,000 20,000 3700 48000 22671.43 200Fecal Streptococci (col/100ml) 5600 14,200 4,600 6,200 15,000 6,000 4600 15000 8600.00Ratio (Fec Coli/Fec Strep) 7.50 3.38 3.15 0.59 0.93 3.33 0.59 7.5 3.15Total Nitrogen as N (mg/l) 1.4 3.16 1.19 1.3 1.67 5.75 7.34 1.19 7.34 3.12Ammonia as N (mg/l) 0.13 0.13 <0.01 0.11 0.01 0.02 0.3 0.32 0.01 0.32 0.13 8.92 1.08Total Phosphorus as P (mg/l) 0.29 1 0.39 0.22 0.54 0.56 1.9 2.5 0.22 2.5 0.93Hardness as CaCO3 (mg/l) 260 110 75 270 200 200 99 99 75 270 164.13Total Suspended Solids (mg/l) 37 937 131 131 166 159 1990 3670 37 3670 902.63Oil and Grease (mg/l) <7 <7 <7 <7 13 <7 11 <7 0 13 3.00 10Aluminum, dissolved (ug/l) 42 355 4 <3 <3 <3 7 <3 0 355 51.00 750Arsenic, dissolved (ug/l) 2 2 <1 2 3 2 1 2 0 3 1.75 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1 <1 <1 <1 <1 <1 0 1 0.13 8.2 0.4Chromium, dissolved (ug/l) 1 2.1 <1 2.5 3 <1 <1 <1 0 3 1.08 901 117Copper, dissolved (ug/l) 3.7 3 1.5 2.9 2.5 2.5 2.7 2.6 1.5 3.7 2.68 23 12Iron, dissolved (ug/l) 109 332 42 15 26 27 13 9 9 332 71.63 1000Lead, dissolved (ug/l) <1 2 <1 <1 <1 <1 <1 <1 0 2 0.25 118 5Manganese, dissolved (ug/l) 238 248 103 328 209 207 87 86 86 328 188.25Mercury, total recoverable (ug/l) <.1 <.1 <0.1 <0.1 <0.1 <0.1 0.1 <0.1 0 0.1 0.01 2.4 0.5Nickel, dissolved (ug/l) 3.9 2.5 1 4.7 3.8 3.7 2.3 1.7 1 4.7 2.95 752 84Selenium, dissolved (ug/l) <1 <1 2 1 <1 <1 <1 <1 0 2 0.38 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1.0 <1.0 <1.0 <1.0 0 0 0.00 8.4Zinc, dissolved (ug/l) 54 49 7 8 7 6 4 3 3 54 17.25 188 172Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of 175 mg/l to 199 mg/l was used for the metals.The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-16PARAMETER (units) WQ STANDARD*MIN MAX MEANUSGS SITE 07001985 WET WEATHER (FIRST FLUSH) RESULTSWATKINS CREEK NEAR BELLEFONTAINE NEIGHBORS - WATER QUALITY ANALYSIS
APPENDIX A3-1WATER QUALITY ANALYSIS10/24/01 10/29/02 3/20/03 11/17/03 3/4/0414:03 00:29 00:29 21:34 11:08ACUTE CHRONICDischarge (CFS) 25 91 30 41 28 7.1 91 43.00pH (units) 7.4 7.5 7.1 7.2 7.5 7.1 7.5 7.34Temperature (deg. C) 13.8 11.2 12.2 16.1 140 0.61 140 38.66Dissolved Oxygen (mg/l) 7.6 7.8 9.6 8.8 9.7 0.61 9.7 8.70 5Fecal Coliform (col/100ml) 30000 28,000 2,800 12,000 0.04 30000 18200.00 200Fecal Streptococci (col/100ml) 11400 12,500 4,560 8,600 0.04 12500 9265.00Ratio (Fec Coli/Fec Strep) 2.63 2.24 0.61 1.4 0.04 2.63 1.72Total Nitrogen as N (mg/l) 2.15 1.73 2.6 5.1 4 0.04 5.1 3.12Ammonia as N (mg/l) 0.08 <0.01 0.04 0.04 0.25 0 0.25 0.08 8.92 1.08Total Phosphorus as P (mg/l) 0.49 0.3 0.25 1 0.8 0.25 1 0.57Hardness as CaCO3 (mg/l) 83 84 170 1,770 1,260 1 1770 673.40Total Suspended Solids (mg/l) 244 83 69 1,770 1,260 1 1770 685.20Oil and Grease (mg/l) <7 <7 <7 <7 <7 0 0 0.00 10Aluminum, dissolved (ug/l) 256 4 <3 9 1,140 0 1140 281.80 750Arsenic, dissolved (ug/l) <1 <1 1 <1 2 0 2 0.60 20Beryllium, dissolved (ug/l) <1 <1 <1 <1 <1 0 0 0.00 5Cadmium, dissolved (ug/l) 1 <1 <1 <1 <1 0 1 0.20 11.6 0.5Chromium, dissolved (ug/l) 1 <1 2.1 <1 1.5 0 2.1 0.92 1207 157Copper, dissolved (ug/l) 2.9 1.9 3 2.9 4.5 0.1 4.5 3.04 32 16Iron, dissolved (ug/l) 262 11 13 25 1,210 0.1 1210 304.20 1000Lead, dissolved (ug/l) 2 <1 <1 <1 8 0 8 2.00 172 7Manganese, dissolved (ug/l) 95 19 10 26 219 0.1 219 73.80Mercury, total recoverable (ug/l) <.1 0.1 <0.1 <0.1 <0.1 0 0.1 0.02 2.4 0.5Nickel, dissolved (ug/l) 1.6 1.2 2.2 5 20 1.2 20 6.00 1017 113Selenium, dissolved (ug/l) <1 3 <1 <1 2 0 3 1.00 5Silver, dissolved (ug/l) <1 <1 <1 <1 <1 0 0 0.00 15.6Zinc, dissolved (ug/l) 70 3 6 5 20 3 70 20.80 255 233Note: To determine Water Quality Standards:A pH of 8.0 and Temperature of 20 degrees C was used for AmmoniaA Hardness range of over 250 mg/l .The Dissolved Oxygen WQ Standard is the minimum acceptable value.A3-1-17MIN WQ STANDARD*MEANMAXUSGS SITE 07019090 WET WEATHER (FIRST FLUSH) RESULTSPARAMETER (units)WILLIAMS CREEK NEAR PEERLESS PARK - WATER QUALITY ANALYSIS
APPENDIX A6-11 SWO-B-13E2-001 -90:12:52.220 38:43:36.726 SE NW15* T46NR7E Maline Mississippi River St. Louis2 SWO-B-10D2-002 -90:10:39.472 38:46:07.217 NE SW36* T47NR7E Mississippi River St. Louis3 SWO-B-09C4-003 -90:10:29.592 38:46:24.598 SW NE36* T47NR7E Watkins Mississippi River St. Louis County4 SWO-B-09C4-004 -90:10:12.275 38:46:37.091 SE SE25* T47NR7E Mississippi River St. Louis County5 SWO-B-08B2-005 -90:07:54.941 38:47:39.523 NW SE20* T47NR8E Mississippi River St. Louis County6 SWO-B-06D4-010 -90:11:26.986 38:49:01.752 SW NE14* T47NR7E Missouri River St. Louis County7 SWO-B-06E2-011 -90:12:16.268 38:49:24.542 SE SE10* T47NR7ESpanish Lake Missouri River St. Louis County8 SWO-C-06E2-001 -90:12:33.340 38:49:34.479 NW SE10* T47NR7E Missouri River St. Louis County9 SWO-C-05E4-002 -90:13:06.023 38:49:54.049 SW NW10* T47NR7E Coldwater Missouri River St. Louis County10 SWO-C-04G2-008 -90:15:55.088 38:51:14.436 SW SE31* T48NR7E Mill Missouri River St. Louis County11 SWO-C-03H2-009 -90:17:09.784 38:51:45.190 SW NE36* T48NR6E Missouri River St. Louis County12 SWO-C-03H2-010 -90:17:10.890 38:51:46.358 SE NW36* T48NR6E Missouri River St. Louis County13 SWO-C-02H4-011 -90:18:09.701 38:52:06.139 SW SE26* T48NR6E Missouri River St. Louis County14 SWO-C-02J3-012 -90:18:27.101 38:52:05.846 SE SW26* T48NR6E Missouri River St. Louis County15 SWO-C-02J3-013 -90:18:29.049 38:52:05.991 SE SW26* T48NR6E Missouri River St. Louis County16 SWO-C-02J3-014 -90:18:32.485 38:52:06.160 SE SW26* T48NR6E Missouri River St. Louis County17 SWO-C-02J3-015 -90:18:51.183 38:52:07.898 SW SW26* T48NR6E Missouri River St. Louis County18 SWO-C-02J3-016 -90:18:55.989 38:52:08.602 SE SE27* T48NR6E Missouri River St. Louis CountyMunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving WaterPage 1 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water19 SWO-C-02J3-017 -90:19:05.966 38:52:10.817 SE SE27* T48NR6E Missouri River St. Louis County20 SWO-C-02J4-018 -90:19:18.559 38:52:12.879 SW SE27* T48NR6E Missouri River St. Louis County21 SWO-C-02J4-019 -90:19:34.161 38:52:14.876 NE SW27* T48NR6E Missouri River St. Louis County22 SWO-C-02K3-020 -90:20:19.611 38:52:14.101 SW SE28* T48NR6E Missouri River St. Louis County23 SWO-C-03K2-021 -90:20:21.950 38:51:41.643 SW NE33* T48NR6E Missouri River St. Louis County24 SWO-C-03K3-022 -90:20:19.835 38:51:27.751 NW SE33* T48NR6E Betty Jane Missouri River St. Louis County25 SWO-C-04K3-023 -90:20:38.622 38:50:37.008 SE SW4* T47NR6E Missouri River St. Louis County26 SWO-C-04K3-024 -90:20:43.397 38:50:30.708 SE SW4* T47NR6E Missouri River St. Louis County27 SWO-C-05K1-025 -90:20:57.309 38:50:15.390 NW NW9* T47NR6E Missouri River St. Louis County28 SWO-C-05K1-026 -90:21:02.203 38:50:09.008 SW NW9* T47NR6E Missouri River St. Louis County29 SWO-C-05K4-027 -90:21:08.782 38:49:59.780 SW NW9* T47NR6E Missouri River St. Louis County30 SWO-C-05K4-028 -90:21:12.364 38:49:55.794 NE SE8* T47NR6E Missouri River Florissant31 SWO-C-05K4-029 -90:21:18.430 38:49:50.120 NW NE8* T47NR6E Missouri River Florissant32 SWO-R-06K1-001 -90:21:32.704 38:49:37.275 SW SE8* T47NR6E Missouri River Florissant33 SWO-R-06L2-002 -90:21:34.722 38:49:33.653 SW SE8* T47NR6E Missouri River Florissant34 SWO-R-06L2-003 -90:21:38.883 38:49:30.203 NW NE17* T47NR6E Missouri River Florissant35 SWO-R-06L2-004 -90:21:42.131 38:49:27.757 NW NE17* T47NR6E Missouri River Florissant36 SWO-R-06L2-005 -90:21:46.968 38:49:25.729 NE NW17* T47NR6E Missouri River St. Louis CountyPage 2 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water37 SWO-R-06L2-006 -90:21:56.908 38:49:22.037 NE NW17* T47NR6E Missouri River St. Louis County38 SWO-R-06L2-007 -90:22:02.077 38:49:19.969 NE NW17* T47NR6E Missouri River St. Louis County39 SWO-R-06L2-008 -90:22:11.348 38:49:16.280 SW NW17* T47NR6E Missouri River St. Louis County40 SWO-R-06L1-009 -90:22:26.159 38:49:12.848 SE NE18* T47NR6E Missouri River St. Louis County41 SWO-R-06L4-010 -90:22:36.976 38:49:12.421 SE NE18* T47NR6E Missouri River St. Louis County42 SWO-R-06L4-011 -90:22:52.033 38:49:10.657 SW NE18* T47NR6E Missouri River St. Louis County43 SWO-R-06L4-012 -90:22:56.625 38:49:10.517 SE NW18* T47NR6E Missouri River St. Louis County44 SWO-R-06L4-013 -90:22:59.145 38:49:10.720 SE NW18* T47NR6E Missouri River St. Louis County45 SWO-R-06L4-014 -90:23:07.813 38:49:10.852 SE NW18* T47NR6E Missouri River St. Louis County46 SWO-R-06M3-015 -90:23:19.252 38:49:06.818 SW NW18* T47NR6E Cowmire Missouri River Hazelwood47 SWO-R-06M4-016 -90:24:43.454 38:49:08.439 SE NE14* T47NR5E Missouri River Hazelwood48 SWO-R-09P2-017 -90:28:24.065 38:46:55.242 SW SE29* T47NR5E Missouri River Bridgeton49 SWO-R-10P2-018 -90:28:40.704 38:46:10.566 SW SE32* T47NR5E Missouri River St. Louis County50 SWO-R-11P1-019 -90:29:04.376 38:45:23.492 NW SW5* T46NR5E Missouri River Maryland Heights51 SWO-R-11Q3-020 -90:29:30.541 38:44:56.638 NE NE7* T46NR5ECreve Coeur Missouri River Maryland Heights52 SWO-R-15R2-021 -90:31:43.186 38:42:04.657 SE NE26* T46NR4E Missouri River Maryland Heights53 SWO-R-15R3-022 -90:31:50.232 38:41:36.584 SE SE26* T46NR4E Missouri River Maryland Heights54 SWO-R-16R1-023 -90:32:14.423 38:41:07.666 NE SW35* T46NR4E Missouri River Maryland HeightsPage 3 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water55 SWO-R-16S4-025 -90:33:30.871 38:40:46.246 SE SW34* T46NR4E Missouri River Chesterfield56 SWO-R-16T3-026 -90:34:14.101 38:40:41.369 NW NE4* T45NR4E Bonhomme Missouri River Chesterfield57 SWO-R-16T4-027 -90:35:02.970 38:40:45.292 SW SW33* T46NR4E Missouri River Chesterfield58 SWO-R-16U4-028 -90:36:56.970 38:40:54.707 SW SW31* T46NR4E Missouri River Chesterfield59 SWO-R-16W2-030 -90:39:30.432 38:41:09.550 NE SE34* T46NR3E Missouri River Chesterfield60 SWO-R-18W4-031 -90:40:20.634 38:38:56.127 NE NW15* T45NR3EMissouri River via Unamed TributaryWildwood61 SWO-R-20W2-032 -90:39:40.122 38:37:48.053 SE NE22* T45NR3EMissouri River via Bonhomme CreekWildwood62 SWO-R-20W3-033 -90:39:36.419 38:37:39.477 NE SE 22 T45NR3EMissouri River via Bonhomme CreekWildwood63 SWO-R-20W3-034 -90:39:35.146 38:37:35.988 NE SE 22 T45NR3EMissouri River via Bonhomme CreekWildwood64 SWO-R-20W3-035 -90:39:33.001 38:37:28.172 NE SE 22 T45NR3EMissouri River via Bonhomme CreekWildwood65 SWO-R-20W3-036 -90:39:26.420 38:37:22.679 SW SW 23 T45NR3EMissouri River via Bonhomme CreekWildwood66 SWO-R-21W2-037 -90:39:20.217 38:37:13.464 SW SW 23 T45NR3EMissouri River via Bonhomme CreekWildwood67 SWO-R-22W2-038 -90:39:01.194 38:36:10.917 NE NW 35 T45NR3EMissouri River via Bonhomme CreekWildwood68 SWO-R-22W2-039 -90:39:01.306 38:36:05.197 SE NW 35 T45NR3EMissouri River via Bonhomme CreekWildwood69 SWO-R-22W3-040 -90:39:01.456 38:35:53.631 SE NW 35 T45NR3EMissouri River via Bonhomme CreekWildwood70 SWO-R-22V4-041 -90:38:52.333 38:35:53.388 NW SE 35 T45NR3EMissouri River via Bonhomme CreekWildwood71 SWO-R-22V4-042 -90:38:44.499 38:35:50.781 NW SE 35 T45NR3EMissouri River via Bonhomme CreekWildwood72 SWO-R-22V4-043 -90:38:38.621 38:35:47.167 NE SE 35 T45NR3EMissouri River via Bonhomme CreekWildwoodPage 4 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water73 SWO-R-22V4-044 -90:38:32.221 38:35:44.204 NE SE 35 T45NR3EMissouri River via Bonhomme CreekWildwood74 SWO-R-23V1-045 -90:38:45.382 38:35:24.234 NW NE 2 T44NR3EMissouri River via Bonhomme CreekWildwood75 SWO-R-23V4-046 -90:38:46.026 38:35:08.792 SW NE 2 T44NR3EMissouri River via Bonhomme CreekWildwood76 SWO-R-24V4-050 -90:38:25.840 38:34:07.531 SW NW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood77 SWO-R-24V4-051 -90:38:17.216 38:34:07.353 SW NW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood78 SWO-R-24V4-052 -90:38:11.570 38:34:07.237 NE SW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood79 SWO-R-24V4-053 -90:38:09.688 38:34:16.384 SE NW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood80 SWO-R-24V3-055 -90:37:56.127 38:34:19.564 SE NW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood81 SWO-R-24V3-056 -90:37:56.208 38:34:16.836 SE NW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood82 SWO-R-24V4-057 -90:38:08.542 38:34:00.919 NE SW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood83 SWO-R-25V2-058 -90:38:09.078 38:33:53.448 NE SW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood84 SWO-R-25V2-059 -90:37:57.024 38:33:52.585 SE SW 12 T44NR3EMeramec River via Hamilton and Carr Wildwood85 SWO-R-25V2-060 -90:37:48.867 38:33:49.866 SW SE 12 T44NR3EMeramec River via Carr CreekWildwood86 SWO-R-25V2-061 -90:37:47.226 38:33:52.128 SW SE 12 T44NR3EMeramec River via Carr CreekWildwood87 SWO-R-16S3-064 -90:33:00.822 38:40:47.887 SE SE34* T46NR4E Missouri River Chesterfield88 SWO-R-16U3-065 -90:37:30.684 38:40:52.764 SE SE36* T46NR3E Missouri River Chesterfield89 SWO-R-16V2-066 -90:37:46.816 38:40:55.924 SW SE36* T44NR3E Missouri River Chesterfield90 SWO-R-24W3-067 -90:38:58.613 38:34:08.027 SE SW 13 T46NR4EMeramec River via Hamilton and Carr WildwoodPage 5 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water91 SWO-R-24V4-068 -90:38:50.396 38:34:07.935 NE SE 14 T44NR4EMeramec River via Hamilton and Carr Wildwood92 SWO-R-24V4-069 -90:38:34.411 38:34:07.776 SW SE 14 T44NR4EMeramec River via Hamilton and Carr Wildwood93 SWO-R-24V3-070 -90:38:06.293 38:34:20.213 NE SE 12 T44NR3EMeramec River via Hamilton and Carr Wildwood94 SWO-R-25U1-071 -90:37:18.636 38:33:52.032 NW SW 7 T44NR4EMeramec River via Hamilton and Carr Wildwood95 SWO-R-25V2-072 -90:37:17.193 38:33:52.016 NW SW 7 T44NR4EMeramec River via Hamilton and Carr Wildwood96 SWO-R-25U1-073 -90:37:07.881 38:33:51.905 NW SW 7 T44NR4EMeramec River via Hamilton and Carr Wildwood97 SWO-M-37K3-001 -90:20:39.161 38:23:24.814 SW NW10* T42NR6EMeramec RiverMississippi River St. Louis County98 SWO-M-36J4-002 -90:19:25.369 38:24:27.634 NW NW2* T42NR6E Mississippi River St. Louis County99 SWO-M-36J2-003 -90:19:10.249 38:24:44.198 SE SW35* T43NR6E Mississippi River St. Louis County100 SWO-M-35J3-004 -90:18:52.785 38:24:59.346 NW SE35* T43NR6E Mississippi River St. Louis County101 SWO-M-36K4-006 -90:20:51.832 38:24:22.791 SE NE4* T42NR6E Meramec River St. Louis County102 SWO-M-36K1-007 -90:20:52.250 38:24:31.038 NE NE4* T42NR6E Meramec River St. Louis County103 SWO-M-36K2-008 -90:20:48.439 38:24:45.541 SE SE33* T43NR6E Meramec River St. Louis County104 SWO-M-35K4-009 -90:20:45.545 38:25:08.438 SE NE33* T43NR6E Meramec River St. Louis County105 SWO-M-35K4-010 -90:20:47.871 38:25:18.847 SE NE33* T43NR6E Meramec River St. Louis County106 SWO-M-34K4-011 -90:20:51.398 38:25:57.633 NE SE28* T43NR6E Meramec River St. Louis County107 SWO-M-34K2-012 -90:20:34.435 38:26:17.819 NW NW27* T43NR6E Meramec River St. Louis County108 SWO-M-33K3-014 -90:20:17.894 38:26:35.764 SE SW22* T43NR6E Meramec River St. Louis CountyPage 6 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water109 SWO-M-33K3-015 -90:20:16.950 38:26:37.394 SE SW22* T43NR6E Meramec River St. Louis County110 SWO-M-33K3-016 -90:20:06.985 38:26:51.308 NE SW 22 T43NR6E Meramec River St. Louis County111 SWO-M-33K3-017 -90:20:05.773 38:26:54.109 SE NW 22 T43NR6E Meramec River St. Louis County112 SWO-M-33K2-018 -90:20:10.775 38:27:18.699 NE NW22* T43NR6E Meramec River St. Louis County113 SWO-M-32K4-019 -90:21:02.995 38:27:30.887 SW SE16* T43NR6E Meramec River St. Louis County114 SWO-M-32L3-020 -90:21:43.323 38:27:24.589 SW SW16* T43NR6E Meramec River St. Louis County115 SWO-M-33L2-021 -90:22:13.869 38:27:16.908 NW NE20* T43NR6E Meramec River St. Louis County116 SWO-M-32M3-022 -90:23:24.774 38:27:23.679 SW SE18* T43NR6E Meramec River St. Louis County117 SWO-M-32M3-023 -90:23:40.439 38:27:31.568 SE SW18* T43NR6E Meramec River St. Louis County118 SWO-M-30M4-024 -90:24:21.976 38:29:04.838 NW NE12* T43NR5E Meramec River St. Louis County119 SWO-M-30M4-025 -90:24:16.516 38:29:17.562 SW SE1* T43NR5E Meramec River St. Louis County120 SWO-M-30M4-026 -90:24:19.614 38:29:23.572 NW SE1* T43NR5E Meramec River St. Louis County121 SWO-M-30M1-027 -90:24:14.904 38:29:41.522 SW NE1* T43NR5E Meramec River St. Louis County122 SWO-M-29M4-028 -90:24:17.132 38:29:52.436 NW NE1* T43NR5E Meramec River St. Louis County123 SWO-M-29M4-029 -90:24:19.076 38:30:10.487 SW SE36* T44NR5E Meramec River St. Louis County124 SWO-M-29M1-031 -90:24:31.340 38:30:18.318 NE SW36* T44NR5E Meramec River Sunset Hills125 SWO-M-29N2-032 -90:24:50.751 38:30:17.081 NW SW36* T44NR5E Meramec River Sunset Hills126 SWO-M-29N2-033 -90:25:25.774 38:30:25.541 NW SE35* T44NR5E Fenton Meramec River St. Louis CountyPage 7 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water127 SWO-M-29N1-034 -90:25:39.472 38:30:40.561 SE NW35* T44NR5E Meramec River Sunset Hills128 SWO-M-28N4-035 -90:26:10.075 38:30:59.632 SW SW26* T44NR5E Yarnell Meramec River Fenton129 SWO-M-27N4-036 -90:26:07.156 38:31:54.211 SW SW23* T44NR5E Meramec River Fenton130 SWO-M-27N1-037 -90:26:04.104 38:31:56.709 SW SW23* T44NR5E Meramec River Sunset Hills131 SWO-M-27N1-038 -90:26:03.371 38:32:09.679 NW SW23* T44NR5E Meramec River Sunset Hills132 SWO-M-26N4-039 -90:26:00.505 38:32:33.106 NW NW23* T44NR5E Meramec River Sunset Hills133 SWO-M-26N4-040 -90:26:02.901 38:32:34.306 NW NW23* T44NR5E Meramec River Fenton134 SWO-M-26N4-041 -90:26:00.723 38:32:39.100 NW NW23* T44NR5E Meramec River Sunset Hills135 SWO-M-26N4-042 -90:26:03.812 38:32:38.537 NW NW23* T44NR5E Meramec River Sunset Hills136 SWO-M-26N1-043 -90:26:04.664 38:32:48.010 SW SW 14 T44NR5E Meramec River Sunset Hills137 SWO-M-26N1-044 -90:26:11.851 38:32:55.471 NE SE 15 T44NR5E Meramec River St. Louis County138 SWO-M-25O3-045 -90:26:22.763 38:33:21.983 NE NE 15 T44NR5E Meramec River Kirkwood139 SWO-M-25O3-046 -90:26:25.110 38:33:26.467 NW NE 15 T44NR5E Meramec River Kirkwood140 SWO-M-25O3-047 -90:26:31.781 38:33:32.416 NW NE 15 T44NR5E Meramec River Kirkwood141 SWO-M-25O2-048 -90:26:35.919 38:33:34.608 NW NE 15 T44NR5E Meramec River Kirkwood142 SWO-M-25O2-049 -90:26:42.534 38:33:33.904 NE NW 15 T44NR5E Meramec River Kirkwood143 SWO-M-25O3-050 -90:26:54.312 38:33:26.918 NE NW 15 T44NR5E Meramec River Fenton144 SWO-M-25O4-051 -90:27:15.272 38:33:16.850 SE NE16* T44NR5E Meramec River FentonPage 8 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water145 SWO-M-25O4-052 -90:27:21.929 38:33:14.954 SE NE16* T44NR5E Meramec River Fenton146 SWO-M-25O4-053 -90:27:26.425 38:33:13.677 SE NE16* T44NR5E Meramec River Fenton147 SWO-M-25O4-054 -90:27:47.384 38:33:10.581 SW NE 16 T44NR5EGrand Glaize Meramec River Valley Park148 SWO-M-26O1-055 -90:27:49.177 38:33:07.058 NW SE16* T44NR5E Meramec River Fenton149 SWO-M-26P2-056 -90:28:35.093 38:32:44.521 SE SE17* T44NR5E Meramec River St. Louis County150 SWO-M-26Q2-057 -90:29:38.378 38:32:45.711 SE SE18* T44NR5E Meramec River St. Louis County151 SWO-M-26Q2-058 -90:29:46.496 38:32:48.057 SE SE18* T44NR5E Fishpot Meramec River Valley Park152 SWO-M-26Q2-059 -90:29:59.909 38:32:48.423 SW SE18* T44NR5E Meramec River Valley Park153 SWO-M-26Q1-061 -90:30:20.605 38:32:46.464 SE SW18* T44NR5E Meramec River Valley Park154 SWO-M-26Q1-062 -90:30:46.008 38:32:47.206 SE SE13* T44NR4E Meramec River Valley Park155 SWO-M-26Q1-063 -90:30:49.189 38:32:44.750 SE SE13* T44NR4E Williams Meramec River St. Louis County156 SWO-M-26Q1-064 -90:30:54.661 38:32:47.930 SE SE13* T44NR4E Meramec River Valley Park157 SWO-M-26R2-065 -90:31:03.113 38:32:48.857 SW SE13* T44NR4E Meramec River Valley Park158 SWO-M-26R2-066 -90:31:13.034 38:32:49.952 SE SW13* T44NR4E Meramec River Valley Park159 SWO-M-26R2-067 -90:31:24.726 38:32:51.676 SE SW13* T44NR4E Meramec River St. Louis County160 SWO-M-26R1-068 -90:31:50.801 38:32:55.165 SE SE14* T44NR4E Meramec River St. Louis County161 SWO-M-26R1-069 -90:32:02.777 38:32:54.314 SE SE14* T44NR4E Kiefer Meramec River St. Louis County162 SWO-M-26R4-070 -90:31:52.263 38:32:37.415 NE NE23* T44NR4E Meramec River St. Louis CountyPage 9 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water163 SWO-M-26R4-071 -90:31:55.377 38:32:26.165 SE NE23* T44NR4E Meramec River St. Louis County164 SWO-M-26R4-072 -90:32:10.092 38:32:24.356 SW NE23* T44NR4E Meramec River St. Louis County165 SWO-M-26R4-073 -90:32:15.010 38:32:27.142 SW NE23* T44NR4E Meramec River St. Louis County166 SWO-M-26S1-074 -90:33:27.408 38:32:46.596 SW SE15* T44NR4E Meramec River St. Louis County167 SWO-M-26S4-075 -90:33:29.452 38:32:34.739 NE NW22* T44NR4E Meramec River St. Louis County168 SWO-M-26S4-076 -90:33:43.477 38:32:23.564 SE NW 22 T44NR4E Meramec River St. Louis County169 SWO-M-27S1-077 -90:33:54.486 38:32:13.043 NW SW 22 T44NR4E Meramec River St. Louis County170 SWO-M-27S1-078 -90:34:02.892 38:32:10.756 NE SE21* T44NR4E Meramec River St. Louis County171 SWO-M-27S1-079 -90:34:03.832 38:32:06.757 NE SE21* T44NR4E Meramec River St. Louis County172 SWO-M-27T2-080 -90:34:17.343 38:31:57.323 SE SE21* T44NR4E Meramec River St. Louis County173 SWO-M-27T2-081 -90:34:15.736 38:31:55.482 SE SE 21 T44NR4E Meramec River St. Louis County174 SWO-M-27T2-082 -90:34:46.261 38:32:02.836 SE SW21* T44NR4E Meramec River St. Louis County175 SWO-M-27T1-084 -90:35:01.189 38:31:58.946 SW SW21* T44NR4E Meramec River St. Louis County176 SWO-M-27T1-085 -90:35:38.111 38:32:16.667 NW SE 20 T44NR4E Meramec River St. Louis County177 SWO-M-27T1-086 -90:35:41.619 38:32:12.441 NW SE 20 T44NR4E Meramec River St. Louis County178 SWO-M-26U3-087 -90:36:14.127 38:32:27.496 SW NW 20 T44NR4E Meramec River Wildwood179 SWO-M-26U3-088 -90:36:15.680 38:32:27.652 SW NW 20 T44NR4E Meramec River Wildwood180 SWO-M-26U3-089 -90:36:18.271 38:32:27.800 SW NW 20 T44NR4E Meramec River WildwoodPage 10 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water181 SWO-M-26U3-090 -90:36:24.149 38:32:29.178 SE NE 19 T44NR4E Meramec River Wildwood182 SWO-M-26U4-091 -90:37:00.589 38:32:36.315 NE NW 19 T44NR4E Meramec River Wildwood183 SWO-M-27V2-092 -90:37:33.739 38:32:00.265 SE SE 24 T44NR3E Meramec River St. Louis County184 SWO-M-28U1-093 -90:36:59.881 38:31:15.369 NE SW 30 T44NR4E Meramec River St. Louis County185 SWO-M-28U1-094 -90:36:54.108 38:31:11.095 SE SW 30 T44NR4E Meramec River St. Louis County186 SWO-M-28U3-095 -90:36:25.052 38:31:00.654 SE SE 30 T44NR4E Meramec River St. Louis County187 SWO-M-29T1-096 -90:35:43.729 38:30:36.288 SW NE 32 T44NR4E Meramec River St. Louis County188 SWO-M-29T4-097 -90:35:25.252 38:30:12.901 SE SE 32 T44NR4E Antire Meramec River St. Louis County189 SWO-M-26U1-100 -90:37:02.280 38:32:58.598 SE SW 18 T44NR4EMeramec R. via unamed TributaryWildwood190 SWO-M-26U1-101 -90:37:03.581 38:32:58.595 SE SW 18 T44NR4EMeramec R. via unamed TributaryWildwood191 SWO-M-32K4-102 -90:21:12.876 38:27:31.712 SE NW4* T43NR6E Meramec River St. Louis County192 SWO-M-32K4-103 -90:21:26.509 38:27:29.579 SW NW4* T43NR6E Meramec River St. Louis County193 SWO-M-33M1-104 -90:24:36.824 38:27:09.405 NE SW 25 T43NR5E Meramec River St. Louis County194 SWO-M-32N3-105 -90:24:51.732 38:27:26.834 SW NW 25 T43NR5E Meramec River St. Louis County195 SWO-M-25O3-106 -90:26:21.630 38:33:16.417 SE SE 9 T44NR5E Meramec River St. Louis County196 SWO-M-29N2-107 -90:25:32.131 38:30:35.772 SW NE 9 T44NR5E Meramec River Sunset HillsPage 11 of 12
APPENDIX A6-1MunicipalityTownship/RangeCreekNameStormwater OutletsAugust 2007SWO ID Number Longitude Latitude 1/4 1/4 Section Receiving Water197 SWO-M-29N1-108 -90:25:35.427 38:30:38.226 SW NE35* T44NR5E Meramec River Sunset Hills198 SWO-L-31G4-001 -90:16:53.747 38:28:36.443 NE SW7* T43NR7E Mississippi River St. Louis County199 SWO-L-30G4-002 -90:16:47.526 38:29:02.747 NE NW7* T43NR7E Martigney Mississippi River St. Louis County200 SWO-L-29G1-003 -90:16:25.302 38:30:19.223 SW NE31* T44NR7E Mississippi River St. Louis County201 SWO-L-29G1-004 -90:16:19.573 38:30:31.604 SE NE31* T44NR7E Mississippi River St. Louis County202 SWO-L-27G2-005 -90:15:38.094 38:31:58.397 NE SW20* T44NR7ER. Des PeresMississippi River St. Louis County*Interpolated section numberPage 12 of 12
APPENDIX A6-2
OUTLET MAP INDEX
A6-2 Index
A6-2 Sheet A
A6-2 Sheet B
A6-2 Sheet C
A6-2 Sheet D
A6-2 Sheet E
A6-2 Sheet F
A6-2 Sheet G
A6-2 Sheet H
A6-2 Sheet I
A6-2 Sheet J
A6-2 Sheet K
A6-2 Sheet L
A6-2 Sheet M
A6-2 Sheet N
A6-2 Sheet O